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Miles Hurst

Partner
Baker & McKenzie

Biography

Miles Hurst is a leading direct tax expert and a partner in Baker McKenzie's Tax Team in Sydney. He has 18 years' experience in tax.

Miles is recognised as Highly Regarded for General Corporate Tax by International Tax Review World Tax and is ranked as a Next Generation Partner by Asia Pacific Legal 500.

He is an author of Thomson Reuters' Laws of Australia commentaries on International Tax and Planning & Anti-avoidance Measures and has been published in The Australian, Bloomberg, The Australian Federal Tax Reporter, CCH Tax Week, the Daily Tax Report, Global Compliance News and LexisNexis Lexology.

He is also a regular moderator and speaker at tax conferences, including the Tax Executive Institute's Tax Summits, the Asia Pacific Tax Conference and AVCJ's Private Equity and Venture Capital Forum.

Practice Focus

Miles advises on cross-border arrangements, tax reviews, audits and other engagement with the Australian Taxation Office and transactions, funds and restructures.

Miles is known for his technical expertise and commercial acumen.

Representative Legal Matters

  • Advising multinationals on international tax issues, including royalty withholding taxes, tax residency, deductibility of outbound payments, the anti-hybrid rules, permanent establishment issues, the multinational anti-avoidance law, the diverted profits tax and the general-anti-avoidance rule.
  • Advising a large infrastructure investment group on its engagement with the ATO on a variety of income tax risks.
  • Advising a large multinational investment group on an ATO risk review.
  • Advising a global financial services group on an ATO Combined Assurance Review.
  • Advised a global retail group on an ATO Combined Assurance Review.
  • Advised a global fast-moving consumer goods group on an ATO audit.
  • Advising large multinational groups on private rulings and class rulings.
  • Advised Kao Corporation on its AUD 400 million-plus 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.
  • Advised 5E Advanced Materials, Inc. and American Pacific Borates Limited on a restructure, demerger, and successful NASDAQ listing.

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
  • Author, Thompson’s The Laws of Australia income tax service
  • Various articles on tax published in Thomson Reuters, The Australian Federal Tax Reporter, CCH Tax Week, the Daily Tax Report, Bloomberg and The Australian
  • Speaker at various tax conferences including the Tax Executive Institute's Tax Summits, the Asia Pacific Tax Conference and AVCJ's Private Equity and Venture Capital Forum