Jerome Tse

Jerome Tse

Based in our Sydney office, Jerome Tse is a tax partner specialising in taxation disputes, litigation and transfer pricing. Jerome is also King & Wood Mallesons’ global transfer pricing coordinator. 

Jerome advises clients on income tax law including on anti-avoidance, diverted profits tax, taxable Australian property issues, transfer pricing, regulatory access regimes and dispute/litigation strategy. His portfolio includes clients in the banking, mining, oil and gas, and private equity industries. 

The International Tax Review recognises Jerome as a tax controversy leader. He is also recognised as a rising star by Euromoney, and has been awarded Best Lawyer in Tax as published in the Australian Financial Review since 2014. 

Jerome regularly presents papers to professional bodies, including The Tax Institute and the Law Council of Australia. Jerome has been a State Councillor of the Taxation Institute since 2010 and understands the importance of being an active member of the tax community.

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  • The morning after: Dealing with the (Part IVA) Hangover (Wine and Tax Convention, The Tax Institute, June 2013)
  • Who is a resident of Australia? (International Tax Day, Tax Institute of Australia, 29 September 2011 in Melbourne)
  • The Accountants Concession - time for a rethink? (Taxation in Australia, October 2010)
  • Latest Tax Legislation, Cases, Rulings and Announcements relating to Division 152 (Victorian State Convention, Tax Institute of Australia, October 2008)
  • Property development - some key revenue issues (Legalwise, November 2007)
  • Trust law income v tax law income (Taxation in Australia, October 2007)
  • Stamp duty on in-specie distributions from trusts (Television Education Network, April 2007)
  • Property development joint ventures (Victorian State Convention, Tax Institute of Australia, October 2006)
  • Service entities - where to now? (Tasmanian State Convention, Tax Institute of Australia, October 2006)
  • Changes to loss recoupment rules (Taxation in Australia, November 2005)
  • What to do when the ATO/AFP come knocking (Taxation in Australia, July 2005)
  • Tax consolidation, division 7A and the small business concessions (Taxation in Australia, March 2005)
  • Co-operatives and non-profits denied application of mutuality principle (Taxation in Australia, October 2004)
  • Tricks and traps when settling disputes (Taxation in Australia, September 2004).

Recent matters

  • Chevron Australia Holdings Pty Ltd Transfer pricing and debt structuring dispute in the Federal Court of Australia
  • BHP Billiton Ltd Bad debt and limited recourse debt disputes in the Federal, Full Federal and High Courts of Australia
  • RCI Pty Ltd Part IVA litigation concerning a global restructure in the Federal, Full Federal and High Courts of Australia
  • Orica Ltd Capital gains tax dispute in the Federal and Full Federal Court of Australia
  • Commissioner of Taxation v Cajkusic Taxation of trust income in the Administrative Appeals Tribunal, Full Federal Court and High Court of Australia
  • Multinational resource sector client Advised on transfer pricing, revenue/capital, exploration expenditure, PRRT/MRRT and litigation/dispute strategy
  • Large Asian multinational client Adivsed on CGT and Division 855 dispute, including formal mediation, filed in the Administrative Appeals Tribunal
  • Large multinational mining client Advised on transfer pricing issues and dispute/litigation strategy
  • Large public energy client Advised on revenue/capital issues, s264 compliance and audit/litigation strategy
  • Large privately owned group Advised on Part IVA and CGT rollover issues in the context of an ATO audit
  • Multinational food company Advised on Part IVA and consolidation issues in the context of an ATO audit
  • Australian retail group Australian pay-roll tax advice on grouping
  • Private equity groups Advised on taxation of private equity groups
  • Long v Commissioner of Taxation Bona fide redundancy dispute before the Administrative Appeals Tribunal.


  • Member, International Fiscal Association
  • NSW State Councillor and Co-Chair of Education Committee, Tax Institute of Australia.


  • 2005: Masters of Law (University of Melbourne)
  • 2000: Bachelor of Commerce and Laws (University of Melbourne).


Legal insights

On 25 June 2021 the Australian Taxation Office released its draft ruling Income tax: royalties – character of receipts in respect of software (TR 2021/D4).

16 July 2021

It is often said that the price of copper is a barometer of global economic conditions.

24 May 2021

On 12 October 2020, the OECD released a Blueprint for each of the Pillar One and Pillar Two initiatives (Pillar One Blueprint and Pillar Two Blueprint, or together, the Pillar Blueprints) for public...

09 December 2020

In June 2020, the United States pressed “pause” on its participation in the OECD’s Pillar One and Pillar Two initiatives, which are designed as “phase 2” of the OECD’s base erosion and profit...

07 October 2020

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