Hayden Roberts

Senior Associate

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Hayden has been a member of Bell Gully's income tax team for eleven years.

Hayden advises on all aspects of New Zealand income tax law. He has experience advising domestic and foreign clients on various corporate tax law issues, including those arising in mergers and acquisitions, financing arrangements, securitisation structures and employee remuneration arrangements. Hayden prepares and negotiates tax related clauses in sale and purchase agreements, financing arrangements and other documents.

Work highlights

Tax disputes and litigation
Advising clients involved in IRD audits and investigations, and in litigation with the IRD. Recent experience includes:

  • Acting for various taxpayers including Alesco New Zealand and Telstra New Zealand in disputes with the IRD on tax positions adopted in connection with convertible note funding arrangements;
  • 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
  • Acting on behalf of taxpayers in transfer pricing disputes relating to the pricing of inter-company debt.