Three firms, three different bets on the same market shift
Partner promotions in tax controversy are not common. The practice is demanding, the client relationships take years to build, and the cases — fought across the ATO, the Administrative Review Tribunal, the Federal Court and occasionally the High Court — tend to run long. Firms do not invest in this space speculatively. When three of them move in the same direction over eight weeks, something structural is happening.
On 1 July, MinterEllison and Gilbert + Tobin both elevated tax specialists to the partnership.
At MinterEllison, Silvino Gomes joins the partnership in tax controversy after 15 years doing exactly that work at the firm. He advises on ATO reviews, audits, objections and litigation across anti-avoidance, transfer pricing, financing transactions and valuation disputes, with appearances in the High Court, Federal Court and Administrative Review Tribunal. What makes his profile unusual is that he has been on both sides of those disputes: seconded to the ATO's review and dispute resolution group, and with time in-house at one of Australia's largest taxpayers before returning to private practice. His sector focus — energy and resources, pharmaceuticals, software, gambling — covers four areas currently attracting the most intensive ATO scrutiny. MinterEllison claims to run the largest dedicated controversy practice in Australia focused on ATO engagement — a competitive assertion other firms would likely contest, but one Gomes' promotion is designed to reinforce.
At Gilbert + Tobin, Matthew Charman joins the partnership in tax. His work sits on the corporate advisory side — structuring complex transactions, fund structures and cross-border arrangements — the territory where ATO enforcement programs tend to land once disputes crystallise. Charman's promotion makes most sense, though, read alongside what G+T did six weeks before it.
In May, Gilbert + Tobin launched its first dedicated tax controversy practice. Not through an internal promotion but by hiring partner Dioni Perera from EY — five years there after more than a decade at Mallesons — who came with a team of five lawyers. It is an entirely new capability for a firm that has historically kept its tax work on the advisory side.
The Australian Financial Review, which broke the story, described it as a clear bet on where G+T sees the wind blowing. Founder Danny Gilbert called it a response to "an increasingly dynamic tax landscape." Perera told the AFR what is actually driving the work: "At the end of every year I say to myself, 'That's the busiest year I've had.' But it just keeps going up a notch. It's the complexity of our law, it's the uncertainty of our law, coupled with positions taken by the ATO and state revenue offices."
The practice she has built is explicitly oriented toward litigation rather than advice. Charman's arrival in the partnership a month and a half later shows G+T building both sides of the tax capability simultaneously.
Between Perera's arrival in May and the July promotions, Holding Redlich hired partner Michael Patane — a former ATO deputy counsel who helped write the GST laws in the late 1990s. He told the AFR that this year's budget reforms carry the same weight as the GST did: "The GST obviously affected everybody, and these reforms also cross all industry sectors, from commerce, property to investment." His forecast: "It's going to be a busy time."
Three firms, three approaches. G+T building from scratch with a lateral hire and a new practice. Minters promoting the partner who has been doing the work for 15 years. Holding Redlich going straight to an ATO insider.
The ATO's large corporate engagement program raised $4.11bn in total liabilities from public and multinational businesses in 2024-25 — $2.62bn in tax liabilities, $331m in interest and $1.16bn in penalties — plus a further $2.2bn collected voluntarily. Corrs Chambers Westgarth's analysis of the ATO's current posture, published last week, puts 70% of income tax audits at global profit shifting. The 2026-27 Federal Budget added more than $700m in new ATO compliance funding, directed at multinational groups and large taxpayers.
The court list for 2026 shows where the pressure is falling. Bendel is before the High Court — whether unpaid present entitlements to corporate beneficiaries constitute a loan under Division 7A, a decision with broad implications for trust-company structuring. The Full Federal Court has Tabcorp on the TOFA provisions. Withholding tax hearings in Coca-Cola and The Star are under way. Ashurst's tax team notes around 15 other taxpayers with cross-border software issues under active ATO review, with court proceedings expected in coming years. A new Private Equity Program within the Tax Avoidance Taskforce has brought PE and private credit deal structures into the frame for the first time.
The easy read is that all three firms are reacting to Labor's May budget — the reforms to capital gains tax, negative gearing and trust distributions. The budget matters, but it landed on top of an enforcement shift that was already well under way.
Corrs traces it directly: the ATO ran a softer compliance approach through Covid, which let certain structures and interpretations bed in. What followed has been a deliberate return to enforcement, with a wider catchment than previous cycles. Scrutiny once reserved for the top 100 taxpayers has moved through the top 1,000. Patane's point about volume is blunt: when he joined the ATO in the late 1990s, Australian tax law filled one volume. It now fills four.
The budget added momentum to something already moving. Perera's summary to the AFR is about as direct as market commentary gets: "In terms of what I do, and helping clients navigate complex disputes, it's not going to get any easier. It's getting harder."
The 1 July promotions are the most recent confirmation of that. They will not be the last.
