Private Equity

Greenwoods & Herbert Smith Freehills has a team of tax specialists that have a deep understanding of private equity structures and transactions. Our experience covers all aspects of private equity investment including:

  • Fund establishment
  • Tax structuring advice
  • Tax due diligence
  • Negotiation of share sale agreements
  • Structuring of management incentive plans    

Members of Greenwoods’ private equity team have presented at numerous Tax Institute conferences and published articles with The Australian Private Equity & Venture Capital Association Limited (AVCAL) in respect of the taxation of private equity.

We are regularly involved in advising on major Australian private equity transactions.

Private Equity Transactions

Allegro: Sale of The Ghan and Indian Pacific Rail

Greenwoods & Herbert Smith Freehills advised Allegro Funds on the sale of its 70% holding in Great Southern Rail.

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Scape: student accommodation projects

Greenwoods & Herbert Smith Freehills advised private equity firm, Telopea Capital, in relation to the acquisition of two prime sites by Scape Student Living, in which it is a significant investor.

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L Capital: Acquisition of stake in RM Williams

Greenwoods & Herbert Smith Freehills advised L Capital on its acquisition of a 49.9% stake in R. M. Williams in April 2013.

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See more transactions

Private Equity Publications

26 Nov 2019  |  Riposte  |  Financial Services  |  Corporate and Mergers & Acquisitions  |  Private Wealth  |  Private Equity  |  Energy & Resources

Close and remote resemblances in the anti-hybrids rules

A recent Draft Taxation Determination is the first ATO guidance on one of the key elements in the anti-hybrids rules; it has implications for how several parts of the rules will operate in practice.

12 Nov 2019  |  Tax Brief  |  Corporate and Mergers & Acquisitions  |  International  |  Financial Services  |  Private Wealth  |  Private Equity

BEPS 2.0 - Pillar Two moves forward

The OECD has released its consultation document for BEPS Pillar Two on GloBE (the global anti-base erosion tax) as promised when releasing the Unified Secretariat Proposal on Pillar One last month.

07 Nov 2019  |  External Publications  |  Financial Services  |  Corporate and Mergers & Acquisitions  |  Private Equity  |  Private Wealth

Sharpcan highlights problems

The High Court recently handed down its judgment in the Sharpcan litigation (FCT v Sharpcan Pty Ltd [2019] HCA 36, reported at 2019 WTB 44 [1387], a case that raises a well-trodden capital-or-revenue issue, but also touches on the untested ‘black-hole’ rules. The case highlights again the glaring omission of a regime for depreciating wasting intangible assets, and the difficult problems taxpayers can face trying to remedy that defect in our law.

Greenwoods_Sharpcan_article.pdf (394 kb)

06 Nov 2019  |  Riposte  |  Corporate and Mergers & Acquisitions  |  Private Wealth  |  Financial Services  |  Real Estate  |  Private Equity

ATO Challenges Trust Cloning, Again

The ATO has recently issued a Taxpayer Alert aimed at countering a newly-emerging form of ‘trust cloning.’

11 Oct 2019  |  Riposte  |  Corporate and Mergers & Acquisitions  |  Financial Services  |  Private Wealth  |  Private Equity

Thin Capitalisation - Arm’s length Debt Test – PCG 2019/D3

The ATO has now provide the following guidance on the application of the Arm’s Length Debt Test (ALDT) in the thin capitalisation rules.

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Private Equity team

Toby Eggleston



Cameron Blackwood



Aldrin De Zilva

Partner, Head of Projects & Infrastructure


Richard Hendriks

Partner, Head of Corporate and M&A


Sue Ann Khoo