About Clint
Clint Harding practises in the firm’s taxation department with particular expertise in corporate and international tax, the taxation of financial instruments and transactions, and the management of tax audits and disputes with the Australian Tax Office (ATO). His clients have included both public and private organisations, very high net-wealth individuals and not-for-profits.
Clint is also an experienced tax practitioner in both United Kingdom and New Zealand tax law, having spent time at major law firms in both London and Auckland.
Clint holds a Bachelor of Commerce and a Bachelor of Laws from Auckland University and was admitted to practice in 1999. He has also completed a Masters of Taxation at the University of Sydney. Clint joined Arnold Bloch Leibler in 2011 as a senior associate and was appointed partner in 2012.
Clint was awarded the Tax Institute's Tax Adviser of the Year Award in 2018, and recently won the Tax Institute 2023 Community Champion Award for services to the tax profession. He is recognised by Best Lawyers® International, Chambers Asia Pacific and the Legal 500 Asia Pacific in the area of tax law. In addition, Clint has also been ranked as a ”preeminent” tax practitioner in Doyle's Guide in the category of tax.
"Clint is highly responsive and provides excellent advice that appropriately balances the legal and the commercial."
Practice focus
- corporate and international income tax, including the Australian tax implications of mergers and acquisitions, consolidation, group restructuring (solvent and insolvent), investment into and out of Australia, and the application of Australia’s tax treaty network
- taxation issues associated with corporate finance, including the taxation of financial arrangements, including asset finance, structured finance and securitisation
- taxation of trusts and funds, including the operation of the managed investment trust regime
- managing taxation audits, negotiations and disputes with the ATO in relation to income tax and related matters
- taxation issues affecting individuals including the taxation of offshore assets and structures, issues and disputes concerning tax residency and advising on asset protection, and
- employee incentive arrangements and employment related taxes.
Experience
Clint has acted for both domestic and international clients in a wide range of taxation matters, including:
- Zip Co: provided tax advice in relation to its entry into the US market through its $400 million acquisition of New York based BNPL QuadPay Inc;
- ME Bank: provided tax advice in relation to its $1.325 billion sale to the Bank of Queensland;
- Starwood Capital: provided tax advice to US investment firm, Starwood Capital on behalf of Starwood Property Trust, in relation to its first Australian debt deal - a $220 million development facility for a project by international student accommodation specialist, Scape;
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Cyberinc: advised Silicon Valley based Cyberinc on the Australian tax aspects of the sale of the Australian arm of its Identity and Access Management business to KPMG;
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Krispy Kreme Doughnut Corporation: advised US-based Krispy Kreme Doughnut Corporation on its acquisition of the Krispy Kreme Australia and New Zealand franchise business from its founding shareholders, providing tax advice in relation to the acquisition and employee incentive arrangements;
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Nufarm: advised Australia’s largest manufacturer of crop protection products, Nufarm Limited, on its Offering of Senior Unsecured Notes to qualified institutional buyers in the United States, providing tax advice in connection with the debt issuance and on cross-border issues;
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NuLac Foods: advised NuLac Foods - Australia’s leading producer of goat milk products - on the tax aspects of its 100 per cent sale to baby food maker, Bubs Australia, including advising on the tax aspects of the documentation. The vendors were tax residents of a number of jurisdictions which added to the complexity of the tax advice required;
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PIK noteholders of Bis Industries; acted for one of the key stakeholder groups on tax issues associated with the recapitalisation of resource logistics provider Bis Industries, including complex US issues;
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Specialty Fashion Group: provided tax advice to Specialty Fashion Group Limited in relation to the strategic sale of its Millers, Katies, Crossroads, Autograph and Rivers portfolio of businesses to Noni B;
- Arrium Limited: advising Kordamentha and the company on the complex pre-sale restructure of the East Coast Steel business and the implementation of the various ground-breaking deeds of company arrangement. Advising on the sale documentation and diligence issues;
- Executive Channel International: advising on a demerger of the European business, obtaining ATO rulings and advising on all aspects of the $68 million sale of the Australian business to ASX-listed oOH!media Limited;
- Nine Entertainment on behalf of the senior lenders, including the hedge funds Apollo and Oaktree: on the Australian taxation implications, structuring considerations and refinancing associated with the restructure of Nine Entertainment, which saw the senior and mezzanine debt of $3.4 billion that was owed by Nine Entertainment being exchanged for a cash payment and all of the equity in the media group;
- a listed company: in relation to the design and implementation of a cross-border employee share scheme;
- a listed company: in relation to the design and implementation of an executive performance rights scheme;
- AsheMorgan: in relation to taxation issues arising from a series of refinancings/debt restructures in the property sector;
- numerous high-net-worth individuals: in relation to ATO audits and disputes;
- a large family group: in relation to the potential Division 7A issues arising in respect of unpaid present entitlements;
- large domestic and international financiers: in relation to structuring and taxation advice for various domestic and cross-border lending arrangements; and
- various not-for-profit clients: in relation to applications for income tax exempt and deductible gift recipient status.
Directorships & memberships
- Clint is a Chartered Taxation Advisor recognised by the Taxation Institute of Australia. He actively contributes to legislative, technical and policy debate as the Chair of the Institute’s Large Business and International Committee. Clint is a frequent guest speaker and is the author of numerous tax-related articles and publications.
- Member of the Australian branch of the International Fiscal Association (IFA).
- Member of The American Bar Association Section of Taxation.
- Former National Chair of the Taxation Committee of the Business Law Section of the Law Council of Australia.
Awards & recognition
Clint is recognised as a leading lawyer by various international guides to lawyers and law firms, including
- Best Lawyers® International: tax law
- Chambers Asia Pacific: tax
- Legal 500 Asia Pacific: tax
- Doyle’s Guide: preeminent in tax law
- The Tax Institute: Corporate Tax Adviser of the Year, 2018; and
- The Tax Institute: Community Champion, 2023.
