Michael Clough

Michael Clough

Michael Clough is a partner in our Melbourne office where he specialises in income tax issues which arise in the domestic and international capital and debt markets and M&A transactions. He has been closely involved in the development of financial instruments and capital market products.

Chambers Global has recognised Michael’s ‘leading tax disputes practices with significant experience in the Supreme, Federal and High Courts….acting for many of the largest corporations in Australia in high-profile cases’. Specifically, his work includes all aspects of tax audits and litigation such as negotiations and actions in relation to the collection of tax, access to premises, production of documents and tax appeals generally.

Michael has been recognised as a leading individual in the area of Tax by Chambers Global, PLC Which Lawyer? and APL 500. Michael was also recently voted Tax Partner of the Year 2016 by Lawyers Weekly.

Michael has presented papers to universities, legal colleges and professional bodies such as the Australian Society of Certified Practicing Accountants, the Taxation Institute of Australia and the Institute of Chartered Accountants.

Michael has been a Visiting Fellow at the University of Melbourne lecturing in International Tax Law in the Masters of Laws programme.

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Significant Matters

  • Representing Chevron in its landmark transfer pricing appeal, now to be heard by the Full Federal Court
  • Representing TPG in its successful test case on the ability of the ATO to collect tax outside Australia
  • Representing RCI in the Federal and High Courts on its successful test case on Part IVA
  • Representing BHP Billiton in the Federal and High Courts in its successful multi-billion dollar tax claim
  • Settling a number of multi-billion dollar transfer pricing disputes for multinational clients
  • The first infrastructure bonds issued in Australia - The Victorian Hospitals Co-generation project sponsored by National Mutual Funds Management
  • The first demutualisation and listing in Australia of a mutual life company - National Mutual
  • Group reorganisations by various public companies including the transfer of the Custom Credit group into National Australia Bank
  • Successful tax cases including the Orica debt defeasance and NAB defence home loans appeals
  • Acted for General Motors subsidiary, Hughes Corporation, in negotiations on the sale of its satellite TV interests.

Professional Memberships

  • Admitted to practice as an Australian lawyer in all Australian jurisdictions
  • Australian Institute of Chartered Accountants
  • Fellow, Taxation Institute of Australia.


  • 1977: Bachelor of Economics, University of Sydney
  • 1979: Bachelor of Laws, University of Sydney
  • 1979 - 1984: Chartered Accountant advising on large finance related transactions in international and corporate taxation
  • 1985: Master of Laws - University of Sydney
  • 1984 - 1987: Managing Director of an international food company
  • 1987 - present: Partner, King & Wood Mallesons.


Legal insights

The Australian Taxation Office has finalised Practical Compliance Guideline PCG 2017/4 concerning its compliance approach to related party financings affecting multinational groups.

21 December 2017

Following the Chevron judgment, the ATO has released PCG 2017/D4: ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions.

17 July 2017

Analysis of the 2017-18 Australian Federal Budget: key tax changes for corporates and small business, personal tax reforms, and funds and superannuation updates.

09 May 2017

Analysis of the 2017-18 Australian Federal Budget's key foreign investment and international tax changes including an expansion of the multinational anti-avoidance law.

09 May 2017

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