Biography
Dioni is a partner in our Disputes and Investigations group.She specialises in tax controversy and tax dispute resolution. Dioni brings two decades of experience helping large businesses navigate the full life cycle of Australian Taxation Office reviews, audits, objections and litigation, as well as investigations conducted by state-based revenue authorities, drawing on strong relationships with administrators and a clear understanding of how they operate.
Dioni advises on complex disputes involving the tax treatment of financing, intellectual property, investments, transactions and royalties. Her expertise spans across various tax issues affecting large businesses including the general anti-avoidance rule, transfer pricing, capital revenue, capital gains tax, capital allowances, tax losses, R&D and withholding tax. She supports clients from early engagement with revenue authorities to strategic positioning for settlements and litigation, with a focus on managing risk and achieving commercially sound outcomes.
She is an experienced litigator and has conducted matters in the Federal Court of Australia, High Court of Australia and Administrative Review Tribunal.
Dioni advises ASX-listed entities, large inbound multinational groups and large private enterprises across sectors including mining, resources, infrastructure, energy, renewables, consumer and gaming.
Experience
Dioni’s experience includes advising:
- A US listed group in their complex ATO audit in relation to financing and other matters.
- A UK listed entity in their ATO audit contemporaneous with a sale process of Australian assets.
- An ASX-listed entity in relation to a dispute with a state-based tax administrator.
- An Australian subsidiary of a listed group in their complex ATO audits involving intellectual property and financing matters.
- An Australian subsidiary of a listed group in a dispute with a state-based tax administrator.
- An offshore pension fund in relation to an ATO audit concerning certain Australian investments.
- An ASX-listed entity in relation to the tax treatment of certain transactions.
- A large Australian business in relation to the ATO’s treatment of tax losses.
- A confidentially conducted litigation in the Administrative Review Tribunal.
- An ASX-listed entity in relation to certain offshore arrangements.
- A US listed business in relation to Australian operations.
- Commissioner of Taxation v BHP Billiton Ltd and ors – acted for BHP in High Court and Federal Court tax litigation on various matters including finance deductions, bad debt deductions and limited recourse debts.
- Orica Ltd v Commissioner of Taxation – acted for Orica in Federal Court litigation in relation to the application of the general anti-avoidance rule.
- Chevron Australia Holdings Pty Ltd v Commissioner of Taxation – acted for Chevron in its landmark Full Federal Court litigation in relation to related party financing under Australia’s new and old transfer pricing rules.
- Victoria Power Networks Pty Ltd v Commissioner of Taxation – acted for Victoria Power Networks in its Federal Court litigation in relation to the tax treatment of gifted assets.
Awards and Recognition
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The Best Lawyers in Australia 2022
Recognised for Tax