David Pratley

David has specialised in tax for over 25 years advising on transactions and structuring for public and private businesses, multinationals, funds, investors and financiers.

He focuses on tax aspects of M&A, finance (debt, equity & derivatives), international inbound/outbound, real estate (development, investment, commercial & residential), funds management and interaction with tax authorities (rulings, audits, negotiation & disputes). David is experienced in a range of sectors including financial services, private equity, technology, communications, media, agribusiness, turnaround, restructuring and insolvency.

Clients describe him as “a first-rate tax lawyer” having “obvious expertise and experience allied with a positive can-do attitude”. David has been recognised in Asia Pacific Legal 500, Best Lawyers, and International Tax Review’s guide to the world’s leading tax advisers. He previously held senior roles in the international tax group of a Big Four accounting firm in New York and Sydney.


David has advised on tax aspects for:

  • RRC Nominees on $500 million business sale to Sime Darby Group, including tax consolidation and negotiation of extensive tax provisions in the sale documents (click here to read more);
  • Prysm Capital on $125 million investment in Pet Circle co-led by the US PE Fund, including international structure;
  • Envizi Group (leading data and analytics software provider for environmental performance management) on its sale to IBM including international tax, negotiation of extensive tax indemnities and warranties, dealing with capital and funding structure;
  • Shareholders of a leading national consulting group with an enterprise value over $100 million on its leveraged buyout by an international private equity fund. Included advice on capital gains tax rollover and the look through earnout rules as well as negotiating extensive tax indemnities and warranties with a Magic Circle law firm and Big 4 consulting firm.
  • S&P 500 multinational on $3.7 billion takeover of ASX 100 group through scheme of arrangement;
  • Quadrant Private Equity on $400 million + IPO of portfolio company;
  • Leading REIT on $442 million sale of a 75 per cent stake in an office tower. The transaction involved the sale of units in sub-trusts of the REIT. Advised on matters relating to trusts, capital gains tax and distributions to institutional investors;
  • Global banking syndicate including Westpac, ANZ, Mizuho and Sumitomo Mitsui on $2.2 billion in credit facilities used for a leveraged buyout by Carlyle Group;
  • International Investor on dispute/negotiation with the Australian Taxation Office involving cross-border issues, ruling applications, law reform submissions, requests for internal review, formal objections, evidence gathering and analysis, strategic advice, scenario planning and managing the interaction with commercial arrangements between multiple competing stakeholders in the USA, Asia and Australia; and
  • A significant Western Sydney landholder on dealing with pre-capital gains tax land including the restructure of co-ownership arrangements and a partial sale to a Government Authority.

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