Tax controversy
Mayne Wetherell is recognised as New Zealand’s leading tax disputes practice. Our tax experts have acted on some of the most significant tax cases to be heard in the New Zealand courts and on many more cases that have settled.
.png)
As tax authorities become more active in their enforcement, the possibility of tax disputes increases. Our tax experts are familiar with the full range of options for resolving disputes: the pre-litigation disputes process, the mutual agreement process for certain cross-border matters and litigation before the courts.
Most tax disputes are resolved by agreement, either with Inland Revenue or Crown Law, and we are well-placed to advise on the best strategy and timing for settlement. Our experience in preparing for and representing clients in the mutual agreement process and in litigation before the courts enables us to advise up-front on the best strategy and to support our clients in managing the process so as to achieve the most efficient outcome.
Our services
Tax audits and information requests
Tax disputes
Judicial review
Transfer pricing
Customs and excise
Warranty and indemnity and tax risk insurance
Work Highlights
Advised on a dispute over the scope of a clause indemnifying a recipient of a payment for GST - heard by the High Court in 2025 (insurance).
Advised on a dispute over whether a compensation amount is subject to GST - heard by the High Court in 2025 (disputes).
Advised on a dispute on the deductibility of costs of work undertaken on buildings (to be heard by the High Court in 2026) (real estate and construction).
Advised a US-based software developer in resolving an Inland Revenue investigation in which penalties and prosecution had been proposed (technology).
Advised a multinational group in litigation in an African jurisdiction regarding the deductibility of losses incurred under a swap transaction (multinational).
Advised a vendor of commercial property in a dispute with the purchaser regarding the allocation of the purchase price for tax purposes (real estate and construction).
Advised Inland Revenue on whether certain costs relating to a proposed corporate restructure were capital or revenue in nature (resolved with Inland Revenue without adjustment to the taxpayer’s filing position).
Advised a US headquartered multinational group in a long-running dispute with Inland Revenue, culminating in proceedings before the High Court and a trilateral mutual agreement process before ultimately settling (multinational).
Advised on a dispute concerning the pricing of an intra-group loan (settled during the pre-litigation tax disputes process, following exchange of position papers and initial briefing of experts).
Recognised for excellence, trusted by clients
First tier experience and skills in finding solutions to very difficult and complex transactions and fact patterns. You can have the utmost confidence that you are receiving the very best tax advice.
Recognised for excellence, trusted by clients
Very practical, pragmatic and do a fantastic job of distilling complex matters into clear and easy to understand key points.
Recognised for excellence, trusted by clients
Delivering ‘quality, comprehensive work’, Mayne Wetherell advises clients on tax disputes, M&A transactions, securitisations, tariffs, and regulatory matters. The practice is able to draw on the expertise of the broader firm to enhance its advice to its clients. Wellington-based Brendan Brown, specialising in corporate and international taxation, leads the team alongside Auckland-based Chris Harker, an expert on tax law reform. Tim Stewart specialises in the cross-over between tax and trust law.
Recognised for excellence, trusted by clients
The team delivers quality, comprehensive work while also being able to distill this into an understandable summary.
Recognised for excellence, trusted by clients
Mayne Wetherell's team has the ability to cut through complexity, clearly explain issues and identify solutions.
Recognised for excellence, trusted by clients
Mayne Wetherell are proactive and solution-driven, which enabled us to navigate unforeseen tax challenges and solve these on time.
Recognised for excellence, trusted by clients
Very responsive, highly commercial and completely across all aspects of transactions which gives the client full confidence.
Our experts
Partner
Brendan
Brown
Partner
Chris
Harker
Special Counsel
Tim
Stewart
Related expertise
Let's talk
Whether you need immediate advice or want to explore how we can support your business, we're here to help.
Keep up to date with us
Celebrating promotions across the Mayne Wetherell team
Court of Appeal releases its decision in Hoban v Attorney‑General
Advising Watercare on major financing milestones
Launching Extraordinary Pay for our team
Supporting emerging talent in M&A
Creating opportunities
