Stephen Sharpley KC

Profile

Stephen's main area of practice is taxation litigation and he has considerable experience appearing in complex tax matters both at first instance and on appeal. His experience also includes representing clients in various alternative dispute resolution processes including mediation, conciliation and early neutral evaluation as well as at hearings conducted by regulatory and investigatory agencies.  

Stephen has a personal interest in matters involving mathematical, scientific and technical issues and has appeared in a number of cases involving valuation, complex financial instruments and the mining and oil and gas industries.

Stephen holds first class Honours and Masters degrees in Law and a degree in Science majoring in pure mathematics. Prior to coming to the bar he was a senior associate at Mallesons.

Reported tax cases he has appeared in include:

• Commissioner of Taxation v SEPL Pty Ltd (ATF the SFT Trust) [2025] FCA 581 - on appeal [2026] FCAFC 36
• Commissioner of Taxation v S.N.A. Group Pty Ltd [2026] FCAFC 10
• Hall v Commissioner of Taxation [2025] ARTA 600 - on appeal [2026] FCAFC 43
• Esso Australia Resources Pty Ltd v Commissioner of Taxation [2024] FCA 87 - on appeal [2024] FCAFC 151
• Mylan Australia Holding Pty Ltd v Commissioner of Taxation (No 2) [2024] FCA 253
• Ultimate Vision Inventions Pty Ltd v Innovation and Science Australia [2022] FCA 606
• Mussalli v Commissioner of Taxation [2020] FCA 544 - on appeal [2021] FCAFC 71
• Bosanac v Commissioner of Taxation [2019] HCA 41
• Caltex Australia Petroleum Pty Ltd v Commissioner of Taxation [2019] FCA 1849
• Coles Supermarkets Australia Pty Ltd v Commissioner of Taxation [2019] FCA 1582
• Deputy Commissioner of Taxation v Leo & Ors [2019] SASC 146
• Sole Luna as Trustee for the PA Wade No 2 Settlement Trust v Commissioner of Taxation [2019] FCA 1195
• Divas Beverages Holdings Ltd v Commissioner of Taxation [2018] FCA 576
• Commissioner of Taxation v Vasiliades [2016] FCAFC 170 
• Commissioner of Taxation v ElecNet (Aust) Pty Ltd [2015] FCAFC 178 - on appeal [2016] HCA 51
• PTTEP Australasia (Ashmore Cartier) Pty Ltd v FCT [2013] FCA 1175 - on appeal [2014] FCAFC 71
• Fowler v Commissioner of Taxation [2013] FCAFC 69
• Sanctuary Lakes Pty Ltd v Commissioner of Taxation [2013] FCAFC 50 
• Sent v Commissioner of Taxation [2011] AATA 198 - on appeal [2012] FCA 382 - on further appeal [2012] FCAFC 187 
• Stewart v Commissioner of Taxation [2013] AATA 845
• Commissioner of Taxation v Traviati [2012] FCA 546
• Deputy Commissioner of Taxation v Bollands [2012] FCA 1050 and [2012] FCA 1148
• Noza Holdings Pty Ltd v Commissioner of Taxation [2010] FCA 990 and [2011] FCA 46 - on appeal [2012] FCAFC 43
• Williams & Ors v State of Victoria & Anor [2012] VSC 585
• Esso Australia Resources Pty Ltd v Commissioner of Taxation [2011] FCA 360 - on appeal [2011] FCAFC 154
• National Australia Bank v Commissioner of Taxation [2011] FCA 44
• Commissioner of Taxation v White [2010] FCA 730 and [2010] FCA 942 
• De Simone v Commissioner of Taxation [2009] FCA 446 - on appeal [2009] FCAFC 181
• ConnectEast Management Pty Ltd v Commissioner of Taxation [2008] FCA 557 - on appeal [2009] FCAFC 22
• Brady King Pty Ltd v Commissioner of Taxation [2008] FCA 81 - on appeal [2008] FCAFC 118