Tax dispute resolution · Melbourne
ATO insight, tested in hundreds of disputes.
A rare combination of experience as an ATO Assistant Commissioner, a Big 4 tax partner and two years embedded in one of Australia’s largest ASX-listed tax functions — bringing insight from all three perspectives to high-stakes ATO matters, from early preparation through engagement to final resolution.
Trusted by
ASX-listed companies Large private groups High-net-wealth familiesThree perspectives
The regulator, the adviser and the tax function — understood from the inside.
Few advisers have sat in all three seats. Paul has led inside the ATO, acted for hundreds of clients as a Big 4 tax dispute partner, and spent the past two years embedded in the tax function of one of Australia’s largest ASX-listed companies. He understands what each side needs to reach agreement.
01 · The ATO
How the regulator thinks
More than a decade at the ATO, rising to Assistant Commissioner. A working knowledge of the policies, practice statements and approval processes that shape how ATO officers decide.
02 · The Big 4
How disputes are won
Nine years as a PwC Tax Dispute Resolution partner, acting for hundreds of clients across reviews, audits, objections and settlements.
03 · The tax function
What the business needs
Two years embedded in the tax function of one of Australia’s largest ASX-listed companies — managing ATO engagement alongside reporting obligations, governance and the board’s expectations.
Services
Senior judgement for complex, high-value ATO matters.
A premium, partner-led service. Every engagement is directed by Paul, supported by a trusted network of senior specialists where the matter calls for it — for boards, CFOs, heads of tax and the advisers who support them.
01
ATO audits & reviews
Managing risk reviews, audits, information requests and interviews so the ATO sees your position clearly from day one.
02
Tax certainty
Preparing well-argued applications for private binding rulings, submissions, and objections to amended assessments and penalties.
03
Settlement negotiations
Leading negotiations with the ATO, including in-house facilitation and alternative dispute resolution, to reach a commercial outcome.
04
Voluntary disclosures
Getting ahead of problems: structuring disclosures to reduce penalties, interest and reputational exposure.
05
Tax governance
Designing and testing tax risk frameworks that stand up to ATO scrutiny, including reportable tax positions and assurance reviews.
06
Supreme Court of VictoriaExpert witness services
Independent expert evidence to the Supreme Court of Victoria on tax administration matters, including state-based taxes and GST, drawing on senior ATO and Big 4 experience.
07 · In-house support
An extension of your tax team when it matters most
Embedded, senior support for corporate tax functions during periods of high workload — particularly ATO risk reviews and audits, Justified Trust reviews and Top 1000 reviews — so your team keeps business-as-usual on track while the ATO engagement is managed expertly.
Discuss your needsApproach
A disciplined approach to complex ATO engagement.
Assess
An early, candid view of the ATO’s likely position, the technical merits and the realistic range of outcomes.
Strategise
An engagement strategy aligned to your board, audit committee and commercial priorities: certainty, timing, risk and reputation.
Resolve
Direct engagement with ATO case officers and decision-makers to reach a durable outcome, and close the matter cleanly.
Historical positions & remission
Put past positions right — on the best terms.
A considered review of prior-year positions can uncover exposures before the ATO does, and opportunities you may have missed. Where corrections are needed, we manage them strategically, with a clear case for reducing penalties and interest.
Request a reviewReview historical positions
Testing past tax positions against current law and ATO practice to identify risk, quantify exposure and decide the right course of action.
Depreciation timing adjustments
Correcting the timing of depreciation and capital allowance claims across income years, and agreeing the treatment with the ATO.
Penalty remission
Preparing persuasive requests for remission of administrative penalties, grounded in how the ATO actually assesses them.
Interest remission
Seeking remission of shortfall interest and general interest charges where the circumstances support it.
Track record
ATO audits handled
Experience leading and supporting large corporates through ATO audits involving the issues shown — including ATO interviews, position papers, independent review and GAAR Panel hearings, and preparing briefs to counsel.
Recent engagements
Since founding McCartin Advisory in 2023.
Expert witness
Engaged by the plaintiff in a high-profile class action in the Supreme Court of Victoria to provide expert witness services on a range of tax technical and tax administration matters.
Justified Trust
Helped four ASX-listed multinational enterprises move from medium to high assurance ratings in Justified Trust reviews.
Information requests
Prepared responses to large ATO requests for information for three ASX-listed companies over a three-year period.
Interest remission
Secured a $2.5 million remission of general interest charge (in full) after the Commissioner had initially declined the request — achieved through a new technical argument.
Technical position revision
Drafted a detailed submission to the ATO revising an earlier tax technical position, supported by comprehensive evidence.
Major project
Led engagement with the ATO on a range of tax matters relating to a large project for an ASX-listed company.
Director penalty notices
Supported a director facing director penalty notices, with proceedings on foot in the County Court, to negotiate a three-year payment plan with the ATO.
Ongoing in-house support
Currently supporting a large ASX-listed multinational group on international projects, and assisting its Global Head of Tax with internal tax reporting obligations and business initiatives.
About
Paul McCartin
Managing Director Paul McCartin brings more than 25 years of tax experience as a former PwC Tax Dispute Resolution partner and senior ATO executive. He has acted for hundreds of clients in their dealings with the ATO and other regulators.
As a former ATO Assistant Commissioner and Australia's delegate to the Joint International Tax Shelter Information Centre in Washington DC, Paul brings a real view of how the ATO thinks — no guessing how an officer might approach your issue. Most recently, he has spent two years embedded as a consultant in the tax function of one of Australia’s largest ASX-listed companies.
- 2023–presentFounder, McCartin Advisory
- Past 2 yearsEmbedded consultant, tax function of a large ASX-listed company
- 2014–2023Tax Dispute Resolution Partner, PwC
- 2011–2014Director, PwC
- 2010Assistant Commissioner, ATO Melbourne
- 2008–2009Australian delegate, JITSIC, Washington DC
- 2007–2008Assistant Commissioner, Public Groups, ATO
- 2002–2007Senior Director, Rulings Division, ATO
- 2000–2002Tax Policy Unit, ATO National Office, Canberra
Discuss a current or emerging ATO matter.
For Heads of Tax, CFOs and General Counsel: a confidential discussion about an ATO review, audit or dispute, and how we can support your team.
Melbourne · Monday to Friday, 9am–5pm
Registered & accredited
