Expert tax counsel
for complex
matters
For more than 25 years, MGS Private has been the trusted referral for accountants, lawyers and barristers navigating Australia's most demanding federal and state revenue questions — for clients from property developers to Australia's wealthiest individuals and families.
The adviser's adviser
for 25 years
MGS Private Pty Limited has been providing advice to accountants, lawyers, barristers, developers, hoteliers and high wealth individuals for more than 25 years. The proprietor, Christopher Batten, has been in practice since 1998.
Chris was admitted as a Chartered Tax Adviser on 1 July 2012 and has been a member of the Tax Institute of Australia since 21 August 1996. He brings more than a quarter century of hands-on experience across Australia's most complex federal and state revenue matters.
MGS Private provides bespoke solutions in relation to federal and state revenue matters with a particular emphasis on trust law, state tax law, and the restructure of property and business assets — across all Australian jurisdictions.
"By far the largest complaint both MGS and MGS Private hear from new high wealth clients is: I thought my accountant knew all that was required to effectively deal with my affairs."
— MGS Private, on the importance of specialist referral advice- Accounting firms — on behalf of their clients
- Solicitors — structuring, trust law and state revenue matters
- Barristers — instructing on ART and Federal Court proceedings
- Property developers and builders
- Hoteliers and hospitality groups
- High wealth individuals and family groups
MGS Private does not accept direct briefs from taxpayers. Instructions must be provided through an accountant or lawyer.
Six practice areas.
One firm.
MGS Private specialises across the full spectrum of complex federal and state tax matters — with a particular depth in trust law, property restructuring and high wealth individual advisory.
Federal Tax — Restructures & Rollovers
Corporate consolidations and reconstructions, small business restructures, CGT rollovers, value shifting, Division 7A and debt forgiveness. Structuring to avoid unintended capital gains at every stage of a transaction.
State Tax — Land Tax, Duty & Payroll
NSW land tax strategy and trust conversion, stamp duty audits and objections, payroll tax disputes, landholder duty, and property restructuring across NSW, QLD, WA and Victoria — including moving property without duty.
ATO Disputes & Audits
Representation through ATO reviews, complex audits and SNC / Behaviours of Concern investigations. Objection preparation and lodgment. ART (Administrative Review Tribunal) appearances. Briefing and instructing leading tax counsel for Federal Court proceedings.
Property Development Structures
Income tax, GST and duty-efficient structures for developers and builders. Moving retained stock to a separate entity from the development entity. ATO Long Term Construction Contracts. Design and Building Practitioners Act 2020 compliance. Partition problems and alternatives.
Trust Law & Succession
Extending trust vesting dates, amending deeds for succession planning and streaming. Advice on present entitlements and specific entitlements. Establishing Succession Trusts, BOMAD Trusts™ and BONAP Trusts™. Trust cloning for CGT. Advice on trust law as it applies to income and net income.
High Wealth Individuals
Bespoke structuring for significant investment portfolios — property acquisition structures with landholder consequences analysis, debt/equity calibration, debt-laden trust strategies, CGT principal residence exemption maintenance, Private Ancillary Funds and Disability Trusts.
Advisory for Australia's
most complex estates
MGS and MGS Private have been advising high wealth individuals and their advisers for more than 25 years. The approach is fundamentally different from standard practice — because the stakes, the structures, and the consequences are fundamentally different.
- Property acquisition structures that consider landholder duty consequences, debt/equity calibration and debt redraw
- Ability to split and clone structures as investment portfolios evolve
- Avoiding the one-size-fits-all trust — bespoke structures for each situation
- Using accountants and lawyers as conduits to expert specialist advice
- Structuring business entities to avoid Division 7A issues
- Applying for ATO and State Revenue binding rulings where appropriate
- Establishing entities with succession features designed for the next generation
- Seeking Counsel's advice for large-scale transactions
- Debt-laden trusts to fund private asset acquisitions — family home, holiday home, children's homes
- Bank of Mum and Dad Trusts™ to assist children with property acquisition
- Borrowing in trusts to fund distributions for private asset acquisition
- Using the refinancing principle to minimise non-deductible debt
- Maintaining the CGT Principal Residence Exemption across all homes, including former residences that are rented
- Placing most assets or loans over private assets in Succession Trusts to avoid Family Provision Act claims
Why HWIs need specialist advice
The most significant difference between high wealth individuals and standard clients is that HWIs require bespoke solutions for their investment asset structures — not templated, off-the-shelf approaches.
Although bespoke advice can incur greater upfront costs, the income tax, duty and other savings over time are significantly greater than those initial costs — often by an order of magnitude.
- Review of business structures for tax efficiency and asset protection
- Review of Division 7A loan and UPE potential problems
- Review of investment and business property holding structures, debt/equity considerations
- Review of personal asset structures and asset protection
- Review of succession plans and implementation
Federal & state tax services
across all jurisdictions
MGS Private provides specialist advice across every area of federal and state revenue law — from the foundational to the highly complex. All work is undertaken through a referral from an accountant or lawyer.
- Consolidations and restructures (all states)
- NSW land tax advice and strategy
- NSW land tax strategy — trust conversion (investment property)
- NSW land tax strategy — trust conversion (family home)
- NSW land tax strategy — corporate consolidation of unit trust
- Stamp duty audits, objections and appeals (NSW)
- Land tax audits, objections and appeals (NSW)
- Payroll tax audits, objections and appeals (NSW)
- Landholder duty advice
- Investment structuring — bespoke solutions
- Private asset advisory — homes, holiday homes, children's properties
- BOMAD Trust™ and BONAP Trust™ establishment
- Private Ancillary Funds and Disability Trusts
- Holistic estate and succession review
From ATO audit to
ART and Federal Court
MGS Private represents clients through the complete dispute resolution continuum — from initial ATO or Revenue NSW enquiry, through objection, to the Administrative Review Tribunal and Federal Court where required.
ATO Audits & Investigations
ATO reviews of all kinds — including SNC reviews and Behaviours of Concern investigations. Response strategy, document preparation and representation throughout.
Objections & Appeals
Preparation and lodgment of objections to ATO assessments and decisions. Appeals to the ART where objections are disallowed. Written advice on prospects of success.
Revenue NSW Disputes
Stamp duty, land tax and payroll tax audits, objections and appeals. NCAT proceedings. MGS Private appears regularly before Revenue NSW and NCAT.
ART — Administrative Review Tribunal
Full ART representation — preparing the case, managing the hearing and presenting argument before the Tribunal. In appropriate cases, briefing counsel.
Federal Court Proceedings
For Federal Court matters, MGS Private prepares the brief and instructs leading counsel from the NSW Revenue Bar — managing proceedings from commencement to judgment.
Private Rulings
Applications for ATO and State Revenue binding advice where appropriate — particularly for large transactions where certainty is required before committing.
How to engage
MGS Private
MGS Private operates as a specialist referral practice — working exclusively through accountants and lawyers. Direct briefs from taxpayers are not accepted. If you have a client matter that requires specialist federal or state tax advice, contact our Sydney office to discuss the engagement.
Level 7, 77 Castlereagh Street, Sydney NSW 2000 · (02) 9231 5111 · contact@macquariegs.com.au