Qualifications
LLB (Hons), BCA (Hons), Victoria University of Wellington
Admitted
2003, New Zealand
Specialising in tax law, Vivian has 20 years’ experience helping clients with New Zealand tax matters.
Vivian advises on all aspects of taxation with a particular focus on business structuring and reorganisations, mergers and acquisitions, financing transactions and international taxation of inbound and outbound investments.
With a proven track record representing clients in engagements with Inland Revenue, Vivian is experienced in helping clients through Inland Revenue audits and tax disputes, negotiating tax settlements, obtaining binding rulings, and seeking legislative amendments and policy reform.
Vivian is a leading legal expert on New Zealand’s participation in international automatic exchange of information regimes with the US under FATCA and with over 100 jurisdictions under the OECD’s Common Reporting Standard (CRS). She has extensive experience advising clients on the impact of those regimes and assisting banks, managed funds and other financial institutions to comply with their obligations.
In recognition of Vivian’s experience, she is regularly invited to speak at the annual New Zealand Law Society Tax Conference and has been a past Chair of the conference. She is also a regular contributor to the New Zealand Law Journal.
Vivian is recognised as a Leading Lawyer by Chambers Asia Pacific 2024 and as a Rising Star by Legal 500 Asia Pacific 2024.
Recent highlights
Has advised:
- Kiwi Group Holdings on tax aspects of the sale of Kiwi Wealth to Fisher Funds for $310m
- Shell on all tax aspects of the divestment of its New Zealand operations to OMV for $794m
- New Zealand and offshore investors on all tax aspects of their investment in a $400m+ major infrastructure project
- two of the top 10 global fast-moving consumer goods companies on permanent establishment and transfer pricing-related matters
- Kāinga Ora on tax issues arising from their key role in delivering the Government’s priorities for housing and urban development in New Zealand and as New Zealand’s largest housing landlord
- major banks (including ANZ, BNZ, Westpac, KiwiBank) and other financial institutions on their obligations under FATCA and CRS and the design and implementation of their processes and compliance programmes
- companies and multinational groups on the design of their employee share incentive schemes.
Affiliations
- Member of the International Fiscal Association.
