Jessica Pengelly

Jessica is a Chartered Tax Advisor with over 10 years’ experience in tax and revenue law. She works closely with her clients to provide quality, commercial and timely advice.

Jessica practices across a broad range of taxation and revenue law areas, including income tax, capital gains tax (CGT), GST, FBT, Wine Equalisation Tax (WET), excise, superannuation, stamp duty, payroll tax and land tax. She has a particular interest in international tax, corporate transactions, property developments and food, beverage and wine taxation.

Jessica also has extensive experience advising high net worth individuals and family businesses in areas such as succession planning, business restructuring and trust taxation.

Prior to joining HWL Ebsworth, Jessica worked for the ATO and was part of the ATO’s Tax Counsel Network, focussing on international tax and GST issues. Her understanding of tax issues and disputes from the ATO’s perspective gives her clients a strategic advantage when it comes to tax dispute resolution.


Jessica’s experience includes advising:

  • Mid-sized accounting firm on a firm restructure involving CGT roll-over relief, CGT small business concessions, and tax consolidation;
  • Central bank on the application of Australia’s sovereign immunity exemption;
  • ASX-listed wine company on the application of the Australian New Zealand Food Standards Code to the development of innovative alcohol products;
  • a global digital service provider’s Australian structure, including the taxation of permanent establishments, the multi-national anti-avoidance law (MAAL) and royalties;
  • Private company group consisting of trusts and companies on the unwinding of a complex series of intragroup loans, including the application of Div 7A to UPEs and section 99B to foreign trust distributions;
  • Family wine business in litigation with the ATO over Wine Equalisation Tax; and
  • Property developer on a large multi-use property development including theĀ  application of the GST margin scheme rules and creditable use apportionment.

Contact us