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Barney Cumberland
BA LLB(Hons)
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Barney is one of New Zealand’s leading tax lawyers, with close to 30 years’ experience across all aspects of New Zealand's domestic and international tax law. He is a member of the firm’s Board of Management.
Barney advises clients on a wide range of transactions and other non-contentious tax matters, both domestic and cross-border, and involving the private, public and not-for-profit sectors. Barney also assists clients with tax disputes and litigation and advises high net worth individuals and families on trust, asset planning and related tax matters.
Barney works alongside his clients to develop strategies that minimise tax risk without inhibiting commercial objectives. His advice is always practical and seeks to distil complex issues into an easily digestible form.
Barney is a member of the New Zealand Law Society Tax Law Committee; the International Fiscal Association (New Zealand branch); and the International Bar Association Tax Law Committee.
Asia Pacific Legal 500 2025
Tax
Leading Lawyer (Hall of Fame)
Chambers Asia-Pacific 2025
Tax
Leading Lawyer
Work Highlights
Private Sector Advisory
Rayonier, Inc Advised Rayonier on the 2025 c NZ$1.5 billion sale of its 76.99% interest in Matariki Forests, New Zealand’s third largest forestry estate, to interests associated with The Rohatyn Group, a global emerging markets asset management business.
Johnson Controls International
Provided NZ tax advice to Johnson Controls on a complex internal restructuring involving components of its Australian and New Zealand operations and subsequent sale of one part of its New Zealand business.
Flynn Restaurant Group
Advised Flynn on its 2025 complex asset acquisition of the quick service restaurant business carried on under the Wendy’s brand in New Zealand. The purchase made Flynn the exclusive Wendy’s franchisee in New Zealand.
DoorDash, Inc
Principal NZ tax adviser, having guided DoorDash, Inc through its 2021 New Zealand market launch, and subsequently in relation to its expanding New Zealand operations.
Huntington Bank
Specialist tax advice to US headquartered and NASDAQ-listed Huntington Bank in respect of its financing activities that are connected to New Zealand.
Adamantem Capital
Adamantem Capital is a leading Australian private equity firm. We have and continue to provide tax advice to Adamantem on its New Zealand portfolio investments, including Heritage Lifecare, Hellers, Evnex and Ecoware.
Mercury Capital
Mercury Capital is an Australian private equity firm with AU$2 billion of committed capital. Provided tax advice to Mercury in relation to a number of transactions, most recently the sale of its stake in HQ Travel Group
Wet & Forget
As part of Simpson Grierson’s engagement by the founders, Barney and team provided extensive tax input on the 2024 sale of the Wet & Forget Group to NZ private equity firm Direct Capital.
Archer Capital
Advised Archer Capital on tax matters relating to the sale of Aspire2 Group Limited, a leading NZ-based education business, to entities managed by Melbourne-based investment fund, River Capital.
Macquarie Asia-Pacific
Infrastructure Tax advice in relation to the sale of Two Degrees’ mobile passive infrastructure.
NZ Rugby
Transactional tax advice in relation to Project Future, the formation of a commercialisation joint venture with American private equity firm Silver Lake.
Multi-national enterprises
Advised numerous large multi-national enterprises on the impact on their NZ subsidiaries of BEPS related changes to NZ income tax rules and NZ’s remote services and distantly taxable goods GST rules.
High net worth individuals and families
Advised numerous high net worth individuals and families on tax, trust and asset protection matters, including with respect to business succession arrangements, the impact of the Trusts Act 2019 and international and domestic disclosure matters.
Public Sector Advisory
Auckland Council group
Provided tax advice to the Council in relation to multiple projects over many years, most recently on the establishment of the Auckland Future Fund, an inter-generational investment trust to provide long-term benefits for Auckland, and the Council’s gifting to the Future Fund, and subsequent sell-down by the Future Fund, of NZ$1.31 billion of shares in NZX-listed Auckland International Airport, New Zealand’s largest international airport.
Not-for-Profit Sector Advisory
Tait Ltd/Tait International Ltd/Tait Foundation/Tait Contel Charitable Trust
Advised on a significant internal restructuring and the subsequent part sale of the Tait electronics business to JVC Kenwood Corporation.
Skills Inc.
Providing ongoing advice to Skills, New Zealand’s largest industry training organisation, on various acquisitions and its transitional arrangements under the Government’s ROVE reforms.
Waikato-Tainui
Advised Waikato-Tainui on numerous ventures undertaken within the auspices of its charitable trust ownership structure.
Disputes and Litigation
United States Department of Justice Expert witness in relation to New Zealand aspects of a significant international tax case between the US Government and a large US multi-national.
Structured finance litigation
Advocate for a leading NZ bank in its $960 million structured finance tax dispute - Westpac Banking Corporation v Commissioner of Inland Revenue.
Convertible note tax disputes
Represented taxpayers in tax avoidance disputes with the NZ Revenue over financing transactions involving the use of optional or mandatory convertible notes.
