One minute with Richard McGill, Managing Partner of TPEQ.
What’s keeping you busy at work?
I’ve recently taken on the managing partner role at TPEQ, where I’m focused on expanding client relationships, shaping our market strategy across Australia and New Zealand, and leading the firm’s technical direction, particularly in debt pricing and structuring, an area under increasing scrutiny from Revenue Authorities.
What do you know now that you wish you’d known at the start of your career?
That technical brilliance alone won’t carry you far if you don’t build strong human connections along the way. Early in my career, I focused heavily on being technically excellent, assuming that was the key to advancement. But it’s your ability to listen, lead with empathy, and genuinely care about people that makes you trusted, authentic and influential.
What’s your view on international tax reform?
I want to like Pillar Two. I really do. But it’s hard to get excited about a framework that is excessively complex, compliance-heavy, and disconnected from commercial reality. For mid-sized multinationals, the administrative burden is massive. The rules are hard to follow and even harder to explain to non-tax stakeholders.
That said, I get why it’s happening. The simplicity many of us crave would likely understate effective tax rates and fail to satisfy political and public pressure for transparency and tax collections. In that light, the complexity is almost inevitable.
But it’s a long way from intent to implementation. If tax policy continues to evolve in this way, we’re going to need more collaboration, not less, and perhaps a willingness to revisit the balance between precision and practicality.
If you could make one change to a tax law or practice, what would it be?
I’d reform how tax disputes are handled. Too often, taxpayers settle simply to avoid risks or publicity, letting Revenue Authorities push outcomes that may not reflect the law’s intent or arm’s length outcomes. Faster audits, clearer escalation paths and more transparent resolution processes would restore balance and improve system integrity.
Are there any new trends or rules that are causing a problem in practice?
Transparency and enforcement are the dominant themes in TP right now in my region. Revenue Authorities ‘downunder’ are more aggressive than ever and are demanding more data.
As for new rules, the new Australian debt pricing and thin capitalisation rules are a game changer, and not necessarily in a good way. Taxpayers must now determine an arm’s length amount of debt under transfer pricing principles (in addition to arm’s length terms and pricing), as well as under the thin capitalisation tests. In theory, this adds flexibility. In practice, it adds complexity, risk and costs. Taxpayers must navigate potentially overlapping expectations: debt vs equity characterisation, arm’s length pricing and quantum, credit ratings, implicit support assumptions, and thin capitalisation compliance. It’s a murky space, and the ATO’s promised Practical Compliance Guideline isn’t expected until mid-2025.
You might not know this about me but...
I’ve climbed New Zealand’s highest mountain twice and somehow still find wrangling a toddler more terrifying. These days my endurance training consists of negotiating bedtime, assembling flatpack furniture without swearing, and trying to remember where I left my coffee...
One minute with Richard McGill, Managing Partner of TPEQ.
What’s keeping you busy at work?
I’ve recently taken on the managing partner role at TPEQ, where I’m focused on expanding client relationships, shaping our market strategy across Australia and New Zealand, and leading the firm’s technical direction, particularly in debt pricing and structuring, an area under increasing scrutiny from Revenue Authorities.
What do you know now that you wish you’d known at the start of your career?
That technical brilliance alone won’t carry you far if you don’t build strong human connections along the way. Early in my career, I focused heavily on being technically excellent, assuming that was the key to advancement. But it’s your ability to listen, lead with empathy, and genuinely care about people that makes you trusted, authentic and influential.
What’s your view on international tax reform?
I want to like Pillar Two. I really do. But it’s hard to get excited about a framework that is excessively complex, compliance-heavy, and disconnected from commercial reality. For mid-sized multinationals, the administrative burden is massive. The rules are hard to follow and even harder to explain to non-tax stakeholders.
That said, I get why it’s happening. The simplicity many of us crave would likely understate effective tax rates and fail to satisfy political and public pressure for transparency and tax collections. In that light, the complexity is almost inevitable.
But it’s a long way from intent to implementation. If tax policy continues to evolve in this way, we’re going to need more collaboration, not less, and perhaps a willingness to revisit the balance between precision and practicality.
If you could make one change to a tax law or practice, what would it be?
I’d reform how tax disputes are handled. Too often, taxpayers settle simply to avoid risks or publicity, letting Revenue Authorities push outcomes that may not reflect the law’s intent or arm’s length outcomes. Faster audits, clearer escalation paths and more transparent resolution processes would restore balance and improve system integrity.
Are there any new trends or rules that are causing a problem in practice?
Transparency and enforcement are the dominant themes in TP right now in my region. Revenue Authorities ‘downunder’ are more aggressive than ever and are demanding more data.
As for new rules, the new Australian debt pricing and thin capitalisation rules are a game changer, and not necessarily in a good way. Taxpayers must now determine an arm’s length amount of debt under transfer pricing principles (in addition to arm’s length terms and pricing), as well as under the thin capitalisation tests. In theory, this adds flexibility. In practice, it adds complexity, risk and costs. Taxpayers must navigate potentially overlapping expectations: debt vs equity characterisation, arm’s length pricing and quantum, credit ratings, implicit support assumptions, and thin capitalisation compliance. It’s a murky space, and the ATO’s promised Practical Compliance Guideline isn’t expected until mid-2025.
You might not know this about me but...
I’ve climbed New Zealand’s highest mountain twice and somehow still find wrangling a toddler more terrifying. These days my endurance training consists of negotiating bedtime, assembling flatpack furniture without swearing, and trying to remember where I left my coffee...
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