Our People

Tristan Hedley
Manager - Sydney


Tristan is a manager in the international tax and transfer pricing team in Sydney. He is passionate about his work and has a genuine fascination with international tax matters and solving complex problems.

Tristan has a strong background in Australian corporate and indirect tax joining the RSM Sydney tax services team in 2014. He also spent two years in the Farringdon Street, London office of RSM UK.

“My time in the UK was an incredible personal and professional experience. During this time, I was able to work with various multinational clients advising on, developing, and documenting their transfer pricing policies in industries varying from agriculture, health, and IT” he says.

He is responsible for advising on various international tax issues including multilateral instruments, anti-hybrid mismatch arrangements, intellectual property optimisation, thin capitalisation and controlled foreign companies. Tristan explains “I take the time to understand the commercial needs of a business and help my clients navigate the dynamic international tax landscape, developing solutions that are coherent with their strategic direction”.

Tristan is a long-suffering Newcastle Knights supporter and enjoys spending weekends with his family and getting his hands dirty in the garden.

Solutions TRISTAN PROVIDES Tristan Hedley

Tristan provides the following international taxation solutions.

  • Development of transfer pricing policies documentation
  • Advising on hybrid mismatch arrangements
  • Interpretation of tax treaties and the multilateral instruments
  • Business restructuring
  • International financing arrangements
  • Management of controlled foreign companies

Significant projects

  • Advising and implementation of inbound funding arrangements for listed US Groups into the UK and Australia.
  • Delivery of hybrid mismatch arrangements advice to large US groups including advice on the business restructure to remediate the impact of the hybrid mismatch rules
  • Advising on the tax consequences relating to the transfer of significant intellectual property documenting the business restructure risk for start-ups and larger established multinational groups. 


  • Charted Accountant, Chartered Accountants Australia and New Zealand (CAANZ)
  • Tax Institute


  • Bachelor of Commerce – Finance/Management (UNSW)
  • Bachelor of Arts – History/Psychology (UNSW)
  • Graduate Certificate of Chartered Accounting Foundations Chartered Account (Deakin University)

Tax Insights | April 2022 edition

3 May 2022
In our April 2022 edition of Tax Insights, we look at family trust arrangements, the ATO's guidance following LIBOR abolition, and luxury car tax. 

ATO issues guidance following LIBOR abolition

19 April 2022
Last month, the ATO issued guidance designed to assist businesses to understand the common tax implications to consider where changes are made to existing financial arrangements due to the IBOR reform, which most notably has resulted in the repeal of London Interbank Offered Rate ('LIBOR'). 

Hybrid Mismatch Amendments

24 September 2020
Important technical amendments clarifying the operation of Australia’s hybrid mismatch rules received Royal Assent on 3 September 2020. Background In 2015, as part of the OECD/G20 BEPS Project, the OECD released the OECD Action 2 Report which made recommendations to neutralise the effects of hybrid mismatch arrangements. In the 2016-17...

Arm’s length debt test – New ATO position finalised

24 August 2020
The ATO has simultaneously published two documents which now represent the ATO’s views on the application of the arm’s length debt test (“ALDT”) in determining borrowing capacity. TR 2020/4: thin capitalisation – the arm’s length debt test is now the ATO’s authoritative ruling on the ALDT though it focuses on key technical inter...

Australia adopts OECD 2017 Transfer Pricing Guidelines

10 July 2020
Australia’s transfer pricing legislation has now imported the most recent updates to the OECD's Transfer Pricing Guidelines as published on 10 July 2017. This follows Treasury Laws Amendment (2019 Measures No.3) Act 2020 which received Royal Assent on 22 June 2020.  The Act makes the following important changes to Australia’s ...

The broadening of Significant Global Entity definition

26 May 2020
Broadening of Significant Global Entity definition and the potential impact for Australian entities with Private Equity ownership. Following new legislation which received Royal Assent on 25 May 2020, the definition of Significant Global Entity (SGE) has been expanded, and a new definition of Country-by-Country Reporting (CbCR) entity creat...

COVID-19 and transfer pricing issues: Potential JobKeeper Payment Implications

5 May 2020
COVID-19 has had a very adverse impact on the cash flows of many Australian businesses, who will be looking closely at the JobKeeper Payment regime and whether their turnover has declined by the requisite percentage.  Further details are available via the RSM Coronavirus Resource Centre viewed here. Australian businesses that a...

COVID-19 and transfer pricing issues: Financing

5 May 2020
COVID-19 has had a pervasive effect on business and one of the most salient is its impact on a company’s cash flow and funding arrangements. We have separately discussed general transfer pricing issues – here we consider the implications to Australian companies working capital management as well as new and existing long-term funding arrange...

TA 2020/1 - Intangibles: Is your remuneration correct?

28 January 2020
The Australian Taxation Office (ATO) has released its first Taxpayer Alert of the decade in TA 2020/1, which identifies two principal concerns regarding intangibles: arrangements related to the development, enhancement, maintenance, protection and exploitation of intangible assets (known as the DEMPE functions) that have not properly remunera...