John Abrahamson Email & Phone Number

255 George Street, Sydney, Australia

The International Tax Team comprises a core International Tax Structuring practice and dedicated Special Project teams responsible for the implementation of measures to address international tax planning and building International Tax Advice and Capability throughout Public Groups and International Support and Projects.Case team international tax support including debt creation, procurement, marketing, service and IP hubs, IP migration structures, group treasury centres, hybrid securities and instruments, and withholding tax avoidance. Preparation of sample large corporates requests for information (RFI) and case team explanation notes.Analysis of international tax planning examples. Identification of tax structuring from case teams and preparing related analysis. Presentation of related tax planning structures to BEPS CbC Reporting teams, Treasury and the OECD. Network development including International Risk Clusters, CbC Reporting, International Transparency, and Tax Counsel Network teams. Capability development with international tax planning presentations in Sydney, Melbourne, Canberra, Brisbane, Newcastle, Adelaide and Perth. Development of the International Tax Topics series, presentations on Upstream Oil and Gas structures, and US tax planning structures.OECD support including hybrid mismatches, aggressive tax planning, mandatory disclosure rules, presentation expert at the OECD BEPS Global Tax relations event, Seoul, South Korea, in 2017, Pillar 2 Capability and Risk Analysis.

Sydney, Australia

John Abrahamson is a Tax Partner at Sheltons-SITTI.John is a qualified lawyer with 25 years’ experience in international taxation, working in structured finance with the Commonwealth Bank of Australia for 9 years as well as Baker & McKenzie, KPMG, and Arthur Andersen. He has upstream oil and gas international tax experience with Maersk Oil and Gas as Director of International Taxation, for Denmark, Qatar, Norway, Abu Dhabi, Algeria, Angola, Greenland, Brazil, United Kingdom, United States, Kurdistan KRG Iraq, and Kazakhstan, specializing in due diligence, tax planning for mergers and acquisitions, investment finance structures, and oil and gas transfer pricing.As part of his international tax career John has worked in Sydney, Melbourne, Copenhagen, Malta and Hong Kong. John is an expert in international tax planning, mergers and acquisitions, transfer pricing and structured finance transactions.John has presented over 30 Sheltons-SITTI international taxation training courses, including in-house courses for major resources groups and financial institutions in many different countries. He has presented open or in-house courses in London, Aberdeen, Jersey, Paris, Amsterdam, Copenhagen, Zurich, Lugano, Warsaw, Limassol, Hong Kong, Singapore, Kuala Lumpur, Sydney, Melbourne, Perth, Rio de Janeiro, Sao Paulo, Mexico City and Houston.John has Bachelor of Economics, Bachelor of Laws, and Master of Laws degrees. He is admitted as a Barrister and Solicitor in Australia, and a member of the International Fiscal Association, and Chartered Tax Advisor with the Taxation Institute of Australia.

International Tax Risk Management and Planning for Maersk Oil's upstream oil and gas. I provide international tax risk management, mergers and acquisitions, tax planning and structured finance advice for Maersk Oil's current upstream oil and gas activities. Maersk Oil has active offshore oil and gas exploration and production in countries including Denmark, United Kingdom, United States, Brazil, Qatar, Norway, Oman, Norway, Algeria, Angola and Kazakhstan. This role includes completion of international tax due diligence and tax planning for oil and gas acquisitions, initial country entry tax due diligence and structure planning for specific countries in North America, Central Asia and West Africa. I also provide international tax advice on tax litigation matters in Africa and Central Asia, tax structuring for Floating Productions Storage and Offloading (FPSO) vessels, providing quarterly and annual tax reporting from Maersk Oil operations in nine countries, coordinating transfer pricing review of Maersk Oil operations, and review of USA structuring and carry forward exploration costs.

Copenhagen Area, Denmark

International Tax Director at Sheltons-SITTI in Denmark. John has presented the Structured Finance and International Taxation Courses for Sheltons-SITTI for over seven years in many locations including London, Amsterdam, Copenhagen, Zurich, Paris, Nice, Rio de Janeiro, Sydney, Jersey, Lugano, Singapore and Hong Kong. He has also presented on mergers and acquisitions and on the Taxation of Electronic Commerce for Baker & McKenzie in Hong Kong, Bangkok and Kuala Lumpur.

My role included origination, product development, and negotiation of large cross border bank to bank transactions. I was the first Bank executive assigned to be resident in Malta, and Director of the five Malta companies. This included negotiating with Maltese Tax, Corporate, and Financial Authority regulators. The CBA Malta companies had assets exceeding AUD4b on completion of the assignment with an extremely successful income flow. The role included origination in meeting and negotiation with members of other banks to consider new transactions. Legal work including liaising with Group Legal for share subscriptions, loan agreements, swap documentation, General Meetings and Board Meetings and related resolutions and Board minutes. Product development included reviewing regulatory capital, accounting and taxation implications of proposed investment and funding transactions, including Australian and international taxation issues. These include developing European exempt income and funding, Australian exempt income and funding, and tax sparing opportunities. Negotiation and deal conclusion included negotiating terms with counterparties and internal discussions with CBA Group Risk, Group Taxation, Group Treasury and Group Legal.

Tax planning including mergers and acquisitions, restructuring, research and development, financial institutions and products, litigation and revenue negotiation. This included successful application for Bank Product Ruling for Share Market Lending Facility, reviewing geared equity investments, advice on prospectus, reviewing the basis of interest deductions and negotiations with Australian revenue authorities. Structured financing proposals for acquisition of Hayman Island resort in Whitsunday Island group, Queensland. Advice on acquisition of gas business, acquisition structures, structured financing and cross border leasing, hybrid structures and funding instruments, restructuring the Australian subsidiary including capital gains tax, hybrid and double dip structures, Western Underground Gas Storage, compensation payments and successful resolution of stamp duty investigation. Eastern Gas Pipeline, advising on participation in the Eastern Gas Pipeline project in Victoria and New South Wales. Advice on Australian infrastructure bonds scheme, finance structure and taxation for acquisition of Australian spectrum licences, thin capitalisation and state transaction taxes, financing structure and trust requirements for German investment in Australian commercial properties, capital gains tax and fiduciary reporting, taxation of equity swaps, dividend streaming and franking credit trading provisions, options and other derivatives, debenture withholding exemptions. Drafting taxation clauses relating to contracting operations in the Australia Indonesia Timor Gap Treaty zone of cooperation.

Tax advising on International and Hong Kong taxation issues, structuring for cross border investment, taxation of derivatives, and corporate and individual tax compliance. This included review of Asia Pacific licensing and royalty structures and related Asia Pacific deductions for royalty payments, advising on taxation position of the undersea fibre optic laying in Hong Kong waters, taxation reporting and exposure, advising on China representative offices, Asia Pacific taxation of aircrew transfers relating to Subic Bay and Singapore regional headquarters concessions. Advised on on Hong Kong capital management, use of agents, offshore profit claims and funding arrangements. Advice on Hong Kong taxation, source of profits, quarantining offshore income and related funding issues. Personal tax planning for major hotel group senior executives including introducing the Hong Kong housing allowance program. Tax planning for high net worth individuals residing in Hong Kong particularly for US and Chinese related family members.

Tax advising for financial institutions, fund managers and trading companies on Hong Kong and international tax issues, and corporate tax compliance for European bank branches, reviewing offshore customer accounts for Hong Kong investors and related structure and administration. Advice included reviewing group funding structure and advising on Hong Kong interest deductions and local tax planning, successful negotiations with Hong Kong revenue authorities concerning group structure and related interest deductions.Advice to major German Banks on Hong Kong taxation, offshore profit issues, taxation of derivatives and advisory services income structured finance products relating to asset transfers and debt creation.Successful negotiations concerning offshore profit claims on brokerage, derivatives and advisory fee income. Reviewing Hong Kong leveraged leasing provisions relating to non recourse debt for lease of aircraft engines.

Advising on capital gains, superannuation, stamp duty, payroll tax, royalty agreements, withholding tax, tax audits and property transactions. Advising Australia's largest retailer on tax audit powers and assistance in preparation for the audit. Advising high net worth family business owners on Australian tax and discretionary trust planning. Preparing real property transfers and related legal documentation and related litigation.

Tax advice and compliance for corporates and individuals, including capital gains tax, dividend imputation, thin capitalisation, and corporate and trust tax returns.Expatriate tax compliance and tax planning for US based individuals. This included Australian tax advice for high net wealth Australian clients in professional legal practice, taxation compliance and advice for large US and Australian multinational groups based in Australia, and accounting, corporate reporting and family trust distributions for high net worth family farm businesses.

Phd - Doctor Of Philosophy, Faculty Of Law

Activities and Societies: PhD completed at the Faculty of Law, Australian National University. My Thesis topic was Joint Development.

Llm - Master Of Laws, Law

Llb - Bachelor Of Laws, Law

Bec - Bachelor Of Economics, Economics

Education record