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Senior Associate

Paul Windeatt

LLB(Hons) MA


P+64 9 977 5024

M+64 21 240 9240

Paul Windeatt

Paul is a senior associate in the tax group. He has more than 20 years' experience advising and assisting corporates, trusts and individuals on the NZ domestic and international tax aspects of acquisitions, investments and divestments.

Paul is also very experienced in assisting with clients on tax and excise duty disputes, including taking matters through the tax disputes resolution process, court proceedings and negotiating settlements.

Paul has been  deeply involved in some of the most significant, complex, and multi-year transactions and tax-related disputes.

  • Asialaw Leading Lawyers Tax 2018 - Leading Lawyer
  • Asia Pacific Legal 500 Tax 2016 - Rising Star

Examples of work - advisory

  • Acquisitions - advising and negotiating tax clauses in agreements for investment in NZ companies and businesses 
  • Multi-level marketing - advising overseas-based multi-level marketing enterprises on the New Zealand tax implications of entering the New Zealand market and providing structuring advice
  • Return to NZ - advising high net worth New Zealand citizens, long absent from New Zealand, on the NZ tax implications of their return to New Zealand and providing each with tax-efficient structuring advice
  • Naval frigates - advising on the tax and excise duty implications of repairing French naval frigates in New Zealand
  • Harvard Management Company, Inc (investment arm of Harvard University) - tax advice on its New Zealand forestry and farming investments, including the sell-down of its stake in Kaingaroa Forest to Canadian pension fund Public Sector Pension Investment Board
  • New Line Cinema (NLC) - part of Simpson Grierson’s team that was the sole NZ advisor to and negotiator for NLC on the NZ financing structure for The Lord of the Rings film trilogy

Examples of work - litigation

  • Major NZ oil company - excise duty disputes with New Zealand Customs, where proceedings were filed with the Customs Appeal Authority
  • Convertible note tax disputes –settled tax avoidance disputes with the NZ Revenue over financing transactions involving the use of optional or mandatory convertible notes
  • International arbitration - senior member of international team (New York, London, NZ) acting for US defendant in a major international arbitration arising from tax-advantaged NZ financing transactions
  • Tax avoidance rebuttal - worked with Litigation partner in representing a leading NZ bank, culminating in successfully striking out proceedings commenced by Yandina Investments, relating to the equitable assignment of an aircraft lease to Yandina, where Yandina alleged tax avoidance - Yandina Investments Ltd v ANZ National Bank and Others
  • Life insurance - using NZ’s tax dispute resolution procedures, won dispute with Inland Revenue over application of life insurance tax rules to a bespoke financing arrangement
  • Financial arrangement rules - further success with pre-litigation tax dispute process, concerning application of financial arrangement tax rules to a UK structured settlement sum following personal injury
  • Mortgagee sales - counsel for financier in the High Court and Court of Appeal in the leading GST case on the priority for payment of GST from the proceeds of a mortgagee sale – Edgewater Motel Ltd v CIR
  • Capital or revenue? - assisted Queen’s Counsel in significant tax case concerning the deductibility of gas pipeline work – CIR v Auckland Gas