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Andy Bubb

Partner
Melbourne
About

Andy focuses on resolving complex tax disputes, particularly for large multinationals. He has market-leading expertise in contentious international tax and transfer pricing matters, particularly the application of Australia's anti-avoidance rules, transfer pricing and tax treaties. He has wide experience in ATO dispute processes, having represented clients in various ATO processes and successfully negotiated settlements.

Andy has been recognised by various industry bodies, including winning the International Tax Review's award for APAC Tax Litigation Rising Star in 2025 and being listed by Doyle's Guide as a Recommended Tax Lawyer.

Areas of FocusTaxEnergy and Natural ResourcesTechnologyInfrastructure, Construction and TransportConsumer Goods, Food and Retail
Professional QualificationsBarrister and Solicitor of the Supreme Court of VictoriaSolicitor of the High Court of Australia

EXPERIENCE

  • Advising on an ATO audit of a US MNE in the technology sector focussing on royalty withholding tax and permanent establishment issues.
  • Advising various multinationals (including several Fortune 500 companies) in relation to the royalty withholding tax and diverted profits tax implications of the decision by the High Court of
  • Australia in Commissioner of Taxation v PepsiCo, Inc [2025] HCA 30.
  • Advising on an ATO audit of a US MNE in the retail sector focussing on treaty shopping and transfer pricing.*
  • Advising on an ATO audit of an Australian infrastructure asset owned by foreign pension and sovereign wealth funds focussing on trust taxation, general anti-avoidance rule and transfer pricing issues.*
  • Advising on an ATO audit of a global energy company focussing on transfer pricing, the general anti-avoidance rule, the multinational anti-avoidance rule and the diverted profits tax for two global restructures.*
  • Advising on an ATO audit of a US MNE automotive manufacturer focussing on capital gains tax / land-rich, general anti-avoidance rule and transfer pricing issues.*
  • Advising on an ATO audit of an ASX-listed entertainment client focussing on its UK business disposal, CFC rules and the general anti-avoidance rule.*
  • Advising on an ATO and state revenue office audits of a technology / gig economy client focussing on whether its workforce were employees or contractors.*
*Experience gained from a previous company
Languages
  • English
Education
  • Chartered Tax Adviser, The Tax Institute, 2015
  • Bachelor of Laws (Hons), Monash University, 2011
  • Bachelor of Commerce, Monash University, 2011

Publications and media

Seminars

Presentations

  • Co-presenter, "PepsiCo and Taxing IP: Where to from here?", Corporate Tax Association National Convention, 15 October 2024. 
  • Co-presenter, "Navigating Intangible Assets from a tax and TP perspective", TP Minds Sydney, 2024.
  • Co-presenter, "The Modern ATO Audit: Everything, Everywhere All At Once", Corporate Tax Association National Convention, 9 October 2023. 
  • Co-presenter, "Managing Transfer Pricing Controversy and Disputes", TP Minds Sydney, 2022.

Media

 

My latest insights

Publication
Abstract architecture DC_PPT_1910x520

OECD Updates to the Manual on Effective Mutual Agreement Procedures 2026

19 February 2026

Connect

Phone

+61 3 9274 5054
(Work, Melbourne)
+61 431 353 325
(Mobile)
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