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David Johnston

Partner
Auckland
About

David leads DLA Piper’s New Zealand tax team and helps domestic and international clients manage tax issues arising from complex transactions, investment structures, W&I insurance, fund formation and cross-border growth. He works with major New Zealand corporates, multinational businesses, private equity firms, financial institutions, fund managers, infrastructure investors and high-growth companies. David’s practice covers mergers and acquisitions, capital raisings, restructurings, inbound and outbound investment, tax disputes, investment funds and employee share plans.

His work often involves aligning New Zealand tax outcomes with wider international structuring and commercial objectives, drawing on DLA Piper’s global tax network where clients require coordinated cross-border support.

David also assists clients with Inland Revenue engagement, including voluntary disclosures, tax rulings, tax enquiries and disputes. He has appeared in the Taxation Review Authority and the High Court.

Areas of FocusTaxInvestment FundsMergers and AcquisitionsFinancial ServicesInsuranceTechnologyReal Estate
Professional QualificationsBarrister and Solicitor of the High Court of New Zealand, 2002Solicitor of the Senior Courts of England and Wales, 2008

EXPERIENCE

  • Supporting Amber Infrastructure on the formation of a New Zealand-focused infrastructure fund understood to be the first Active Investor Plus-approved infrastructure fund of its kind in New Zealand, with a stated fund size of USD300 million. The matter required a cross-border fund structure capable of accommodating domestic and offshore investors, including investors with differing tax profiles across New Zealand, the United States, Australia and the United Kingdom.
  • Acting for Investment Services Group and its shareholders on the sale of a 75% stake in ISG to Shaw and Partners, supporting Shaw and Partners’ strategic entry into the New Zealand market. The tax work formed part of a broader financial services transaction involving a major wealth and funds management business with more than USD4 billion in assets, and required close coordination across tax, corporate and regulatory workstreams.
  • Working with Tracksuit, a high-growth New Zealand-headquartered market research business, from its early growth stage through to its Series B capital raise and international expansion. The work included tax input on the capital raise, cross-border investor documentation and employee share scheme issues for a rapidly scaling business valued at more than NZD400 million, with more than 200 employees and operations expanding into Australia, the United States and the United Kingdom.
  • Supporting Ingka Investments on the New Zealand tax aspects of its acquisition of Mangakahia Forest and Ormond Valley Forest, a substantial forestry acquisition involving approximately 12,790 hectares in Northland and approximately 81 hectares in Gisborne. The mandate involved tax issues under the forestry regime, the emissions trading scheme tax rules and land tax rules, integrated with the wider corporate, real estate and commercial workstreams.
  • Providing New Zealand tax support to Campbell Global, part of JP Morgan, on complex cross-border investment structures relating to New Zealand forestry assets. The work has involved Cayman, Luxembourg, Australian and New Zealand tax considerations, including financial arrangements rules, withholding tax exposure, base erosion risk and deductibility of funding costs associated with offshore capital flows.
  • Assisting W&I insurers on New Zealand tax issues arising from insured transactions in New Zealand and internationally. This work includes SPA reviews, tax due diligence review, policy negotiations, underwriting support and broader New Zealand tax advice for insurers participating in transactions ranging from approximately NZD50 million to more than NZD4 billion.

Awards

  • Highly Regarded individual by ITR World Tax
  • Ranked by Chambers Asia-Pacific for Tax
  • Named as a leading individual by The Legal 500

Education
  • Victoria University of Wellington, LLB
  • Victoria University of Wellington, LLM
  • Victoria University of Wellington, BSc

Memberships And Affiliations

  • Barrister and Solicitor of the High Court of New Zealand, 2002
  • Solicitor of the Supreme Court of England and Wales, 2008
  • Member of the Law Society Tax Committee
  • Member of the Financial Services Council Tax Committee
  • David has presented at the New Zealand Law Society Tax Conference, the Chartered Accountants Australia and New Zealand (CAANZ) annual tax conference, the International Fiscal Association (New Zealand Branch), the International Fiscal Association Australian Tax Conference and the ITR Asia Pacific Tax Conference

My latest insights

Events
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Navigating Tax Strategies in the Asia Pacific Region

24 June 2026 .2 minute read

Publication
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Budget 2026, the budget for a secure future

28 May 2026 .8 minute read

Publication
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DLA Piper Financial Futures Report – A New Zealand Lens

24 April 2026

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Phone

+64 9 300 3812
(Work, Auckland)
+64 21 911 146
(Work)