Expert in Tax Law and Taxpayer Defence, Trusts law and Trusts disputes

Geoff Clews is one of the few New Zealand barristers who specialize in acting for clients facing serious tax problems, both civil and criminal. He has done so for more than 40 years. Geoff leads the tax practice at Old South British Chambers, assisted by his colleague in Chambers, barrister Sam Davies.

Geoff’s practice covers all aspects of tax advice and controversy. He advises clients in the course of Inland Revenue investigations. He conducts the formal aspects of the statutory tax disputes process. He litigates tax and related issues, and defends criminal tax charges, before the Courts at trial and appellate levels. His practice also includes trusts related advice, disputes and litigation.

In all these matters Geoff applies focused and objective analysis of his client’s situation, an honest judgment of their position, strategic thinking and compelling advocacy.

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  INTERNATIONAL RECOGNITION

GLOBAL LAW EXPERTS, TAX BARRISTER OF THE YEAR, NEW ZEALAND, 2025

CHAMBERS ASIA PACIFIC, GLOBAL, LEADING PRACTITIONER AT THE TAX BAR
2008 - 2025

INTERNATIONAL TAX REVIEW, TAX CONTROVERSY LEADER, 2011 - 2025

BEST LAWYERS IN NZ 2017 - 2025. AUCKLAND TAX LAWYER OF THE YEAR 2017

FINANCE MONTHLY, NZ TAX LAWYER/FIRM OF THE YEAR, 2018

FINANCE MONTHLY, NZ CIVIL AND CRIMINAL TAX LAWYER OF THE YEAR, 2019

  LAW REVIEWS EXPERT PANEL/LEXOLOGY IN DEPTH 2018 - 2025,
TAX DISPUTES AND LITIGATION

WHO'S WHO LEGAL/LEXOLOGY INDEX, CORPORATE TAX (CONTROVERSY), 2019 - 2025

WINNER, CCH TAX AWARD, NEW ZEALAND LAW AWARDS, 2012

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Our Expertise

Tax secrets? Sometimes people cut corners with their taxes. Not everything gets returned as it should be. Claims are over stated or income is suppressed. These tax secrets fester away but you can do something about them if you act in time and with the right help. We deal with these issues all the time.	Being investigated by IRD? A tax investigation can be intrusive, frustrating and worrying. Tax investigation powers are intimidating but have to be exercised within limits. These procedures have to be managed carefully to avoid cost and increased tax risk. We manage tax investigations daily.	In a dispute with IRD? The statutory tax disputes process is complicated and involves strict time frames for the exchange of notices and “sudden death” deadlines. If you miss one of them, you can lose all your rights of dispute and if you omit something it will be difficult to raise it later. We know these procedures thoroughly.

Challenging a tax assessment? A tax challenge is formal civil litigation in the Taxation Review Authority or the High Court. It requires a winning strategy, tactical sense and persuasive advocacy. We try to keep clients out of court but, if it is needed, we advocate for taxpayers against the IRD at all Court levels.	Being prosecuted by IRD? Tax crime is serious and involves the real risk of prison. If you have not disclosed your default to the IRD and it prosecutes you, an effective defence or mitigation is vital. We appear regularly to defend people who have been charged with tax offenses.	Is IRD after a tax debt? Tax debts can mount up very quickly if they are not managed. Penalties and interest can virtually double the size of a debt in 3 to 4 years. Settling payment terms with the IRD is not a normal commercial negotiation. We deal with this issue for clients all the time.

Need legal tax advice? Tax laws are particularly complicated because they have to cover every aspect of commercial life. Parliament is always changing them to meet new demands and to close loopholes. Many commercial transactions require a tax sign off and responsible taxpayers will seek advice before adopting a course that could have material tax outcomes. Sound tax advice can be insurance against some tax penalties.	Trust issues or disputes? Some trusts are well managed and some are not. Trustees do not always understand their obligations and beneficiaries are sometimes disadvantaged by trustee decisions. The new Trusts Act changes the legal landscape. Trustees' duties are clearer and beneficiaries have expanded rights to know about a trust. Importantly, trust disputes can now be resolved using alternative dispute procedures of mediation and arbitration saving the costs of litigation.	Charities The Department of Internal Affairs Charities Service vets, registers and oversees charities. Defining the purposes of an organisation in a way that qualifies as charitable can require professional advice. Adverse decisions as to charitable status may be appealed to the High Court which has marked out a more particular approach to the scope of charitable purposes.
Cook Islands tax and trusts disputes Geoff Clews holds permanent admission to the Bar of the Cook Islands High Court. He is available to act as counsel in tax disputes and litigation with the Cook Islands Revenue Management Division, and litigation related to the Cook Islands International Trusts and Companies regimes.	The new age of forensic tax investigation Inland Revenue has announced the establishment of a new unit to begin building the forensic investigation capabilities that its new START computer system permits. In a nod to the TV series of the same name, the unit is called CSI, standing for Compliance Strategy and Innovation.	IR's High Wealth Individuals Project In 2023 this operation targeted some 400 wealthy New Zealanders seeking a great deal of information about their affairs. Although the project has not progressed after a change of government, IR is still monitoring the affairs of HWI taxpayers and deploying big tech to do so.

Professional reviews

Geoff Clews...He's the guy you call after Inland Revenue bursts through your doors and seizes your computers, certain already after months of covert surveillance that you're fiddling your taxes... - Auckland's Best Lawyers, Metro Magazine, August 2008

To read more of this article, click here.

Geoffrey Clews of Old South British Chambers is active across a comprehensive range of advisory and representational mandates in the taxation sphere, being particularly well known for his work on behalf of clients facing especially serious tax-related issues in both the civil and criminal spheres. He is described as "extremely competent" by one source and as "a distinguished lawyer with a broad practice" by another. Chambers Asia Pacific. New Zealand, the Tax bar, 2022, 2023, 2024; Chambers Global,2025.

"Highly respected".... "great to work with"... "approachable and well versed at thinking outside the box"... "he really performs well." Chambers Asia Pacific reviews 2018-2020.

Geoff Clews stands out as a go-to for civil and criminal tax disputes thanks to his three decades of experience in the field. Who's Who Legal, Asia Pacific, 2021

Geoff, since a young age I have understood the benefit of retaining very capable people, especially when it comes to challenging issues that are quite consequential. Right from the beginning I knew you, like others before, were going to fulfill that same need. Too many people use middle level advisers, get average advice with no connection to the senior ranks of the other party and despite the lower charge out rate, end up paying more. - Client communication on successful completion of a long running case, May 2017.

Geoff Clews has been a long-established leader in the tax law arena, in both a civil and criminal context and is one of the few New Zealand barristers who has developed a strong reputation in the area. His expertise extends from every part of tax issues and at all appellate levels, achieving significant recognition for his expertise in the area, including for his advocacy. - LawFuel "Top Barristers Nudging the Power List," February 2019.

To see other reviews, click here.

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Employment and other opportunities at Old South British Chambers

Junior or trainee barrister interested in gaining experience in all aspects of contentious tax practice. For more information, click here.

Barrister's room in Chambers available - character space of 43 square metres, with adjacent secretarial bay and use of all Chambers facilities. Available now. For more information, click here or contact Geoff Clews on 021- 627-737.

Latest tax and trusts news

16 April 2026 - The latest three yearly long term insights briefing has just been published by IR. The media has highlighted IR's suggestsions that on present settings more revenue will be needed and that an increase in GST and a wider capital gains tax are the best options to provide that.  The briefing notes one key challenge is population ageing, which is expected to place increasing pressure on public finances. But most tax bases are alreday in play so new bases would have a large degree of overlap with existing ones and give rise to difficult trade-offs. IR's suggestion is that the future focus should be on bringing capital that is not yet taxed into the income tax net and increasing GST with compensating transfer to address the inherently regressive nature of GST. To read the briefing, click here.

31 March 2026 - Inland Revenue has published seven new statements setting out guidance on the meaning and application of the several shorfall penalties that may be applied under the Tax Administration Act. Though the guidance is not substatively different from prior advice, it is updated wth recent case law and examples. To read more, click here.

24 March 2026 - Changes to Common Reporting Standard requirements have been announced with effect from 1 April 2026. These will now include indirect investments in crypto-assets through derivatives and investment vehicles, specified electronic money products and central bank digital currencies. New guidance has been published for the coming reporting year. To read it, click here.

12 March 2026 - The Minster of Finance has confirmed that the proposals for taxing long-standing unpaid shareholder loans will not proceed in their present form (see 8 December note below). Further work is to be done to consider how best to address the issue after coalition partners in the Govrnment expressed opposition to the proposals either entirely (NZ First) or in part (ACT). The proposals were flawed in several respects but how to tax long-standing shareholder loans, espcially when there is no prospect of them being repaid, remains a live issue. For the present, Inland Revenue is likely to address this in the field using other tools such as deemed dividend rules and the general anti avoidance rule.

16 February 2026 - In November 2025, the OECD released updates to the model double tax convention, introducing a new analytical framework for assessing when a remote employee’s home office may constitute a “permanent establishment” (“PE”) of their employer in another jurisdiction. These changes are particularly relevant for organizations with cross‑border remote or hybrid work arrangements. to read more (with acknowledgements to Aird and Berlis), click here.

29 January 2026 - Inland Revenue is apparently tracking how its audit activity impacts the social contacts of its audit targets. It is monitoring how close contacts of an audited taxpayer learn of the audit and increase their own compliance as a result, through voluntary disclosure. To read more click here.

To view past tax and trusts news, click here.

Case notes

Tax and trusts law is constantly developing through Court and tribunal decisions. To read our latest case notes, click here.

To read our case note on the recent Supreme Court Family First decision, click here.

To read about company directors being personally liable for company tax debts, click here.

Commentary and publications

2025 Chambers & Partners Tax Controversy Guide for NZ

The latest edition of this international publication, whose New Zealand contribution was originally written and is annually revised by our team, was released on 16 May 2025. To read the latest publication including the New Zealand chapter, click here

Tax Disputes and Litigation Review

Our 2025 contribution to this publication is now part of Lexology In Depth. To read it, click here. Note that registration may be required. If you would like a copy of earlier text, please contact us.