Graham Murray

Partner Auckland

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​​​​​​​​​​​​​​Graham’s areas of focus include the taxation of corporate restructuring, mergers and acquisitions, cross-border investment arrangements and joint venture structures. He has expertise in the taxation of financing arrangements, in particular securitisation structures and cross-border lending/debt acquisitions.

Graham has engaged with the Inland Revenue Department for various clients in contentious tax disputes and obtaining binding rulings, determinations and indicative views. His other areas of expertise include funds management, including a detailed working knowledge of the portfolio investment entity (PIE) rules, and double tax treaty issues. Graham also advises a diverse range of private clients and new migrants on a range of New Zealand personal tax issues.

Work highlights

Sale of Carter Holt Harvey pulp, paper and packaging business
Advised Rank Group and its subsidiary Carter Holt Harvey on the taxation aspects of the sale of the New Zealand pulp, paper and packaging business to the Oji Holdings Network Corporation and Innovation Network Corporation of Japan for NZ$1.037 billion. In particular, advising on pre-sale restructuring, transaction sequencing and negotiating tax clauses in the sale and purchase documentation.

Acquisition of Transpacific Industries Group
Advised on tax matters on the acquisition of the Transpacific business in a competitive bid process, including conducting purchaser tax due diligence, advising on ownership and debt structuring matters, negotiating tax clauses in the sale and purchase agreement and reviewing tax assumptions in a purchaser's financial model.