Ian Fullerton

Ian Fullerton

Ian is recommended in the 2017 and 2018 Doyle’s Guide to leading tax barristers in NSW. His primary area of practice is the taxation of financial and international transactions and trusts including superannuation trusts. He also advises on tax matters generally and on regulatory, administrative law, trust law and commercial law matters including matters involving civil penalties and criminal sanctions.

With more than 30 years’ experience in commercial, tax risk management and advisory roles, and with a deep understanding of financial accounts and the banking and finance industry, Ian is well placed to analyse the commercial law and taxation implications of complex transactions.

Ian is a qualified chartered accountant. He started his professional career with Price Waterhouse (now PwC) in London before moving to Sydney. At PwC, Ian specialised in the taxation implications of cross-border transactions. He then spent 14 years in the banking industry. As a Managing Director in the Wholesale Banking and NAB Capital Divisions of National Australia Bank, Ian led or contributed to the development of a number of capital markets transactions. At Commonwealth Bank of Australia, Ian was a member of the Group Tax team and in that capacity assessed and managed tax risk on a wide range of transactions. In 2012, Ian joined Ashurst Australia and was involved in advising on the tax implications of many large financial and corporate transactions.

Ian is the author of the chapter on the taxation of trust income in Ford and Lee: The Law of Trusts, and of chapters on the taxation of trusts, debt and equity, financial transactions, asset-based finance and tax planning in the Thomson Reuters Australian Tax Handbook.

He has recently delivered papers on aspects of the branch profit attribution rules and the transfer pricing rules in the income tax law and on Australian trust law in the context of Australian income tax law.

Select Cases

Gleeson, in the matter of Kingston Property Holdings Pty Limited (No 2) [2017] FCA 974 (with R D Marshall SC)

Tech Mahindra Ltd v Federal Commissioner of Taxation (High Court special leave application with A H Slater QC)

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