Qualifications
LLB (Hons), BCA (Hons), Victoria University of Wellington
Admitted
2003, New Zealand
Vivian advises on all aspects of New Zealand taxation, with a particular focus on transactional tax.
Her practice includes mergers and acquisitions, inbound and outbound investments, financing transactions, and business structuring and reorganisations. She also supports clients with operational tax issues.
Vivian represents clients in engagements with Inland Revenue, including obtaining binding rulings, managing audits and disputes, negotiating settlements, and seeking legislative and policy reform.
Vivian is a member of the Tax System Forum, which provides independent expert guidance to the Minister of Revenue on tax policy. She is also a leading legal expert on New Zealand’s participation in international automatic exchange of information regimes, including FATCA and the OECD’s Common Reporting Standard (CRS). She advised almost all of New Zealand’s major banks and other financial institutions on implementing FATCA and CRS compliance programmes in 2014 and 2017, and continues to assist clients with ongoing compliance.
Vivian is recognised as a Highly Regarded practitioner by ITR World Tax, a Leading Lawyer by Chambers Asia Pacific and a Next Generation Partner by Legal 500 Asia Pacific. She is regularly invited to speak at tax conferences and is a regular contributor to the New Zealand Law Journal.
Recent highlights
- Advising New Zealand and offshore investors on the structuring and tax aspects of major infrastructure projects, including submarine cable and renewable energy.
- Advising multinational groups on permanent establishment and transfer pricing-related matters, including applying for and obtaining advance pricing agreements.
- Acting as an independent expert and providing advice on New Zealand taxation in relation to a significant international arbitration claim.
- Advising NZ Post on transactions involving the ownership of the Kiwibank group of financial services entities, including the initial sale of a 47% stake to NZ Super Fund and Accident Compensation Corporation and the later sale of its remaining interests to the Government.
- Advising Kāinga Ora on tax issues arising from its key role in delivering the Government’s housing priorities and as New Zealand’s largest housing landlord.
- Advising major banks (including ANZ Bank, Bank of New Zealand, Westpac, KiwiBank) and other financial institutions on their obligations under FATCA and CRS and the design and implementation of their processes and compliance programmes.
Affiliations
- Member of the International Fiscal Association.
