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Mark Macrae

BCom, MTax (Melb), JD (Mon)

Senior Associate


About Mark

Mark Macrae is a senior associate in the firm’s taxation group.

He provides technical and strategic tax advice to a range of clients including high-net-worth individuals, large private groups, public entities and not-for-profits.

Prior to joining Arnold Bloch Leibler, Mark held various positions with leading accounting firms, and was a Senior Fellow lecturing on tax avoidance in the Melbourne Law Masters program. He was appointed as a senior associate effective July 2019.

Mark is a Chartered Tax Adviser (CTA) and he is also a member of the International Fiscal Association. He holds a Bachelor of Commerce and Masters of Tax from the University of Melbourne, and a Master of Laws (Juris Doctor) from Monash University. 

Practice focus

Mark’s practice focuses on the following areas:
  • Audits and reviews: advising clients on, and managing, all stages of ATO audits and reviews of income tax and GST matters
  • Alternative dispute resolution and litigation: resolving disputes with the ATO regarding tax and administrative issues 
  • Voluntary disclosures and pre-lodgement reviews: advising on and managing disclosures in relation to complex tax issues to the ATO 
  • Income tax advice: advising on the application of income tax law in relation to general and specific anti-avoidance regimes, the debt/equity provisions, Division 7A, cross-border trust arrangements, and
  • Foreign investment issues: advising on, and preparing applications under, the foreign investment regime, and advising on various State and Commonwealth surcharges and taxes imposed on foreign investors.


Mark has acted in a range of matters, including:

Corporate clients

  • Ongoing significant and complex tax disputes involving representations to and appearances before the ATO’s General Anti-Avoidance Rules Panel on Part IVA issues, and settlements of long-running disputes, and
  • Advising a multi-national manufacturer on tax audits and disputes regarding transfer pricing, residency, and the application of the controlled foreign companies regime.

Private clients

  • Acting for large private groups to negotiate with the ATO in relation to the disposal of strategic assets
  • Assisting family groups manage complex structures, including advising on family trust elections and Division 7A, and
  • Pre-lodgement engagement with the ATO in relation to complex cross-border transactions.

Recognition & publications

Take a look at Insights & News articles referencing Mark Macrae