Miles Hurst
Biography
Miles is a partner in Baker McKenzie’s Tax Practice Group in Sydney. He has been advising multinational clients on federal income tax planning, transactions and ATO engagement since 2006.
Practice Focus
Miles is a leading corporate tax lawyer, advising on international tax (including inbound and outbound structures, reorganizations and cross-border payments), transactions (M&A, spin offs, funds and major projects) and engagement with the Australian Taxation Office (ATO) (including rulings, determinations / MAP, reviews and audits).
He is recognised as Highly Regarded in General Corporate Tax by International Tax Review World Tax and is ranked as a Next Generation Partner in tax by Asia Pacific Legal 500.
Miles is an author of Thomson Reuters' commentaries on International Tax, Structuring and Anti-Avoidance. He has also been published in The Australian newspaper, Bloomberg, The Australian Federal Tax Reporter, the Daily Tax Report, Global Compliance News and LexisNexis Lexology and CCH Tax Week.
He is also a regular moderator and speaker at international tax conferences. Miles is known for his techninal expertise and commercial acumen.
Representative Legal Matters
- Advising a large multinational group on the deductibility of stock-based compensation recharge arrangements and application of Australia's imported hybrid mismatch rules
- Advising a large multinational on changes to its Australian operating structure
- Advising a large multinational on the application of withholding taxes to its outbound payments
- Assisting a large multinational industrial group to obtain a private ruling from the Australian Taxation Office (ATO) on the tax treatment of its Australian arrangements
- Advising a global financial services group on a ATO audit
- Advising a large infrastructure investment group on engagement with the ATO regarding corporate dual tax residence issues
- Advising a global infrastructure consulting firm on an ATO audit
- Advising a global technology company on an ATO audit
- Advised Kao Corporation on its AUD 400M+ acquisition of Australian skincare brand Bondi Sands
- Advised Sev.en Global Investments on its circa AUD 1.5 billion acquisition of a 51% interest in ASX listed Coronado Global Resources, Inc. from The Energy & Minerals Group
Professional Honors
- International Tax Review World Tax: Highly Regarded (General Corporate Tax) 2025
- Asia Pacific Legal 500: Next Generation Partner 2020-2025
Professional Associations and Memberships
- Taxation Institute of Australia - Fellow
- Law Society of New South Wales - Member
Admissions
- New South Wales~Australia (2010)
Education
- University of Sydney (LLM Tax) (2015)
- University of Sydney (LLB, Hons) (2006)
- University of Sydney (BSc Adv. Physics) (2006)
Languages
- English