Bevan Miles Bevan Miles

Bevan Miles
Partner
Auckland

Tax
Risk & governance advisory

As the head of our national Tax practice, Bevan advises on a wide range of tax matters. He also leads our Risk & Governance Advisory practice.

Bevan's experience includes restructuring, international transactions and transfer pricing, significant mergers and acquisitions (M&A), financing and capital raising transactions, tax disputes and tax risk management.

His extensive financial services sector experience sees him regularly advising financial services businesses on tax rules applicable to banking, insurance and investments/funds management (including PIE rules).

Prior to working at Chapman Tripp, Bevan was with ASB Bank where he had overall responsibility for the tax affairs of the Commonwealth Bank of Australia's New Zealand group, including ASB and Sovereign Life Assurance. This, combined with his experience in private practice, means Bevan is uniquely placed to understand clients' tax requirements.

Bevan is recognised as a leading lawyer by Chambers Asia Pacific 2021.

Recent highlights

  • Advising a large bank on design and implementation of its CCCFA due diligence policy and related documentation.
  • Advising on managing tax risk. A board requirement was to implement a robust, documented method of managing tax risk. A tax risk management framework was designed and implemented to ensure compliance needs were met. A positive reaction was received, tax awareness raised within the organisation and the levels of tax risk in the business were reduced.
  • Advised on the tax aspects of significant M&A deals, including advising ANZ Bank on the sale of its New Zealand life insurance business; AMP on the sale of its New Zealand life insurance business; Tower on the $197m negotiated full takeover made by Fairfax Financial Holdings; and NZ Super Fund on its 41.1% stake in Fidelity Life Assurance Company Limited for $100m.
  • Advising all parties involved on high-profile securitisations, including the originators (RESIMAC, Turners Automotive Group), trustees (Eclipx, Harmoney), rating agencies (Eclipx, Latitude) and lenders (Thorn/DTR).
  • Assisting multinational groups on permanent establishment and transfer pricing, and related issues arising from high value cross-border arrangements.
  • Advised on funding and related arrangements, including bank regulatory capital, cross-border lending and reinsurance.
  • Advised on all aspects of significant tax disputes with Inland Revenue, including preparing relevant dispute documents, preparing and/or reviewing court documents, managing the discovery process, briefing witnesses, liaising with external counsel and appearing as counsel in High Court proceedings.
  • Obtained binding rulings from Inland Revenue on complex commercial and funding transactions.

Affiliations

  • Member of the Financial Services Council Tax Working Group.
  • Regular presenter at domestic and global tax conferences.
  • Previous Chair of the New Zealand Bankers’ Association Tax Working Group.