Hayden Roberts

Advised Alesco New Zealand and Telstra New Zealand in disputes with the IRD on tax positions adopted in connection with convertible note funding arrangements.

Liaising with the taxpayer rulings and large enterprises divisions of the Inland Revenue Department to obtain binding tax rulings and indicative views for clients.

Reviewing and advising on income tax aspects of various domestic and cross-border transactions. Recent experience includes advising on the taxation clauses in various merger and acquisition documents, securitisation transaction documents, and other financing agreements.

Advising taxpayers on complex income tax issues, including advising investors on the taxation status (i.e. as capital or revenue) of various shareholdings; advising on the potential application of the land taxation rules to parcels of land held by them; and advising on the taxation status and acquisition date of various high value assets.

Acting for Sovereign Assurance Company in its dispute with the IRD on the tax treatment of an international reinsurance arrangement.

Appearing as junior counsel in the Court of Appeal and Supreme Court on behalf of the taxpayer in the Frucor Suntory New Zealand Limited v CIR tax avoidance litigation.

Acting for taxpayers in numerous disputes concerning the capital / revenue boundary, and transfer pricing disputes relating to the pricing of inter-company debt.