Luke Tanner

Luke is an experienced tax lawyer, and has advised clients on international tax matters and cross-border M&A transactions, including reorganizations, due diligence, reviewing financial models and legal agreements, financing and structuring, tax effective profit repatriation and exit strategies.

Luke also has extensive experience in transfer pricing, including handling transfer pricing matters at a Big 4 accounting firm. His expertise includes pricing policies involving profit splits and intellectual property transactions, permanent establishment profit attribution and intra-group financing. He has a particular focus on transfer pricing controversy, including assistance with tax and transfer pricing audits and obtaining bilateral APA and MAP agreements involving many jurisdictions in the Asia Pacific region including Singapore, Malaysia, Thailand, China and Japan, as well as the US, UK and Europe.

Luke has practiced in several Asia Pacific jurisdictions, including Australia and Japan.

• Advised a range of clients on the application for, and conclusion of, bilateral APA and MAP agreements between APAC jurisdictions, including Japan, Singapore, Malaysia, Thailand, and China, and also the US, UK and Europe. Transactions included complex profit splits, valuation issues and issues related to reorganizations and post-merger integration.
• Advised clients on structuring and intercompany pricing when starting operations, restructuring mature operations and exiting. This included design, implementation and defense of tax efficient business models and internal reorganizations including spin offs, mergers and legal entity rationalization.
• Advised clients in the pharmaceutical, financial services, technology and luxury goods industries with respect to tax and transfer pricing audits of their operations in jurisdictions including Australia, Japan and Singapore.
• Advised on intra-group financing, including loan facilities and cash pool structures, and on thin capitalization, withholding taxes, consideration of relevant anti-avoidance legislation as well as pricing.

• American Chamber of Commerce in Japan - Tax Committee Member
• Australia and New Zealand Chamber of Commerce in Japan - Member