Tim Stewart

Tim Stewart

Special Counsel.

Areas of expertise.

– Tax
– Trust Law


LLB (Hons), BCA, Victoria University of Wellington.
MLB, Bucerius Law School and WHU – Otto Beisheim School of Management, Germany.

International experience.

Ogier (Guernsey) 2011 – 2012


ddi: +64 4 260 2233
mob: +64 22 639 6411


Tim advises on New Zealand tax and trust law issues.  His tax practice focuses on financing transactions, securitisations, and customs and excise issues.  Tim also advises high net worth individuals and family trusts on tax and associated trust issues, as well as on the tax consequences of individuals migrating to New Zealand.  His experience includes advising on transactions, obtaining binding rulings from Inland Revenue and representing clients in tax audits, disputes and litigation. 

Tim is a member of the NZLS Tax Law Committee.  He is also a member of the International Fiscal Association and an affiliate member of the Society of Trust and Estate Practitioners. 


  • Westpac, BNZ and ANZ on regulatory capital issuances (bank).
  • Avanti in respect of its securitisation programme (including issuances of residential mortgage backed securities), and wholesale A$ MTNs (non-bank finance).
  • Offshore financiers in relation to the securitisation financing provided to SG Fleet in relation to its acquisition of Leaseplan (non-bank finance).
  • Brockwell Capital in relation to W&I insurance on various acquisitions (various sectors).
  • Various individuals in relation to asset planning on immigration to New Zealand.
  • Various clients in connection with disputes with Inland Revenue and New Zealand Customs.
  • Westpac in its successful application for judicial review of the exercise of Inland Revenue's power to amend assessments (Westpac Securities NZ Limited v Commissioner of Inland Revenue (2014) 26 NZTC 21-118) (bank).
  • BNZ in litigation involving cross-border sale and repurchase arrangements (BNZ Investments Limited v Commissioner of Inland Revenue (2009) 24 NZTC 23,582) (bank).