Specialist tax advisory
A broader view. Clear direction.
Specialist tax advice for business owners, private groups, individuals and advisors.
Where we help
Advice, modelling and lodgement within one engagement.
International tax
Foreign pensions, tax residency, offshore investments, non-resident investors and cross-border business. Our lead practice, drawing on Australian and UK experience.
Explore international taxATO strategy and disputes
Reviews, audits, voluntary disclosures, position papers, objections and settlement, handled with an understanding of what the case team is testing.
Explore ATO strategy and disputesPrivate wealth and family enterprise
Structures, succession, trusts and superannuation, and the family decisions behind them.
Explore private wealthFounder and transaction tax
Deal structuring, CGT, employee equity and implementation, resolved before anything is signed.
Explore founder and transaction taxThe principal
Gavin Quayle
Gavin has more than 17 years of experience in tax across the ATO, Big 4 advisory in London and Sydney, and private practice. Every Hilltop engagement is handled by him directly.
His career spans both sides of the system: eleven years at the ATO, including as a Director in private group compliance and objections, followed by Director-level advisory work in the Big 4. He specialises in international tax for private clients, including individuals and families moving to and from Australia.
From higher ground, the whole shape of a matter becomes visible.
The view from both sides
An advisor who has responded to ATO reviews understands the questions being asked. Someone who has led the teams behind those reviews also understands why they are asked and how a matter is likely to progress. We consider not only whether a position is technically correct, but how it will be read and what evidence it needs.
Preparedness, not opposition
We don't approach the ATO as an adversary. The aim is to understand how the system works, prepare properly and resolve matters on the strongest available footing. The value is not confidential knowledge or special access. It is judgement built over a career spent seeing how tax law is applied.
Clear direction
A broader view is only useful if it leads to a decision. We tell you where you stand, what needs attention and what should happen next. The conclusion comes first, followed by the reasoning and evidence to support it.
How matters unfold
Hypothetical scenarios showing the kinds of matters we are engaged on, and the difference specialist advice makes.
A UK pension, three years after the move
Sarah moved to Sydney after 15 years overseas. Her UK pension was worth A$350,000 when she arrived and A$500,000 three years later, when she asked her financial advisor about bringing it to Australia.
We confirmed the scheme was a foreign superannuation fund, so only the A$150,000 of growth since arrival was taxable. By electing for her Australian fund to pay the tax at 15%, the bill was about A$22,500 instead of A$70,500 at her marginal rate. Had the scheme been treated as a foreign trust without records, the full A$500,000 could have been taxed.
A 15-year-old structure and a family ready for succession
A family had run a profitable business as a sole trader for 15 years. Two adult children were now involved, personal wealth had grown, and the structure offered little asset protection and no clear way to access accumulated wealth without significant tax.
We reviewed the business, holdings and the family's intentions, designed a new structure, and managed the transition in two phases to limit tax and preserve cash. Their existing accountant kept the compliance work.
An ATO review, prepared for properly
A private group received an ATO request covering trust distributions and loans from its company. The group's accountant had handled the compliance well, but had not run an ATO review before.
We tested the positions before anything was sent, identified two gaps in the records, and framed the response around what the case team was actually testing. The review closed without adjustment to the main positions, and the group fixed the record gaps going forward.
The right time to talk to us
We are most valuable before a position becomes difficult or expensive to change.
- You are moving to Australia, or leaving it
- You plan to transfer or draw on a foreign pension
- You hold offshore investment bonds, funds or accounts
- A business or significant asset may be sold
- A family structure no longer fits your circumstances
- An ATO letter, information request or review has arrived
- Your existing advisor needs a specialist tax view
See the whole matter before you decide.
Conversations are confidential and without obligation. You will speak directly with Gavin.