About Clint
Clint Harding leads the firm’s Sydney taxation practice 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 recently awarded the Tax Institute 2023 Community Champion Award for services to the tax profession. He is a current member of the Executive of the Business Law Section of the Law Council of Australia. Clint 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:
- National Veterinary Associates: in relation to the sale of VetPartners to EQT Group;
- Probiotec: in relation to its acquisition by Indonesian-listed company PT Pyridam Farma, by way of scheme of arrangement.
- Netflix Inc: in relation to the acquisition of Animal Logic.
- Centennial Property Group: in relation to the establishment of the B2C Industrial Property Fund.
- AsheMorgan: in relation to tax advice on the acquisition of a $210 million prominent office tower at 310 Ann Street, Brisbane.
- GenesisCare: acted as Australian counsel for the new major equity owners in connection with a debt-for-equity swap as part of a US$2.1 billion restructure.
- An Australian and New Zealand-based property developer: in connection with the purchase of a $51,600,000 development site in Auckland, New Zealand.
- One of the largest industry superannuation funds in Australia, together with some of their subsidiaries: on restructuring their business activities and issues concerning the utilisation of carried forward tax losses.
- ME Bank: provided tax advice in relation to its $1.325 billion sale to the Bank of Queensland;
- 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;
- 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;
- 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;
- numerous high-net-worth individuals in relation to disclosures and settlement negotiations in respect of their involvement in a tax promotion scheme;
- 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
- Who's Who Legal: corporate tax
- The Tax Institute: Corporate Tax Adviser of the Year, 2018; and
- The Tax Institute: Community Champion, 2023.