About Anfeng He
Anfeng advises taxpayers on a broad range of corporate tax issues, with significant experience in both advisory and disputes.
In his advisory work, Anfeng helps taxpayers navigate the Australian income tax implications of their transactions and business structures. In his disputes work, Anfeng assists taxpayers with the full ambit of tax disputation. He regularly manages audits, information requests and evidence gathering, all towards the goal of resolution, whether by a favourable audit outcome, strategic settlement, or resolution via litigation.
His recent experience includes:
- disputes and litigation – conducting litigation in the Federal Court, including Esso Australia Resources Pty Ltd v Commissioner of Taxation [2024] FCA 87 and the settlement of BHP's longstanding marketing operations transfer pricing dispute with the ATO;
- resources sector – advising on complex resources projects, including on the operation of the Petroleum Resource Rent Tax regime and fiscal stabilisation of oil and gas projects in Papua New Guinea;
- equity / debt financing – advising on Bendigo and Adelaide Bank's 2020 offer of capital notes (and 2017 offer of converting preferences shares) and acting for borrowers and lenders on syndicated facility agreements and debenture offers;
- cross-border tax – advising on the operation of the transfer pricing, thin capitalisation and controlled foreign company provisions; and
- pro bono – assisting charities with applications for registration and endorsement for tax concessions.
Anfeng is a Fellow of the Tax Institute of Australia and holds a Master of Laws from the University of Melbourne.