In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like “fixed place of business”.

The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

In this episode of Taxed Out, <a href="https://www.ashurst.com/en/people/vanja-podinic/">Vanja Podinic</a> and <a href="https://www.ashurst.com/en/people/colin-little/">Colin Little</a> explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like &ldquo;fixed place of business&rdquo;.
The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

The commercial world is always changing and the legal landscape never stands still. Keeping pace with all those changes, and knowing how they affect your organisation, is a big responsibility and a challenging task. Ashurst Legal Outlook will keep you at the forefront of the most pressing legal issues, offering insights from legal experts across our international network.

The commercial world is always changing and the legal landscape never stands still. Keeping pace with all those changes, and knowing how they affect your organisation, is a big responsibility and a challenging task. Ashurst Legal Outlook will keep you at the forefront of the most pressing legal issues, offering insights from legal experts across our international network.

A podcast series that will keep you across the global trends and local issues that are shaping the legal landscape and impacting organisations.

Ashurst Legal Outlook Podcast

Ashurst Legal Outlook

Data centres sit at the intersection of permanent establishment risk, transfer pricing, DEMPE, intangibles and withholding tax. 

Taxed Out: How and why data centres are becoming a global tax flashpoint 

The construction phase of wind projects can be fraught with time, cost and quality issues. In this episode, we speak with two industry insiders about some of the common pinch points in the construction of a wind project and explore steps that help minimise the likelihood of contractor/developer disputes occurring.

Ashurst’s Michael Weatherley is joined by two special guests to discuss construction risks in wind projects, including how they can best be  anticipated and mitigated to avoid or manage disputes between developers and contractors. George Fisher is a senior contentious construction solicitor at SSE Renewables and Kia Hua Tan is a senior legal counsel at Seatrium Limited.

The trio considers the unique nuances and curve balls that can hamper wind projects, including  tight margins and split procurements driving complex interface risks. As the discussion makes clear, careful and precise planning is required to allow for things like extreme weather, vessel availability and rising offshore logistics costs.

On cost volatility, both our guests stress the importance of clarity in fixed-price contracts and price escalation mechanisms to avoid surprises later on. They also flag quality issues across package boundaries, suggesting that these require detailed interface matrices and harmonised dispute provisions to avoid protracted blame games between contractors.

To listen to this and subscribe to future episodes in the Caught In The Crosswinds mini-series, search for “Ashurst Legal Outlook” on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at ashurst.com/podcasts.

To learn more about the issues raised in this episode, read this article on the Ashurst website.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

The construction phase of wind projects can be fraught with time, cost and quality issues. In this episode, we speak with two industry insiders about some of the common pinch points in the construction of a wind project and explore steps that help minimise the likelihood of contractor/developer disputes occurring.
Ashurst&rsquo;s <a href="https://www.ashurst.com/en/people/michael-weatherley/">Michael Weatherley</a> is joined by two special guests to discuss construction risks in wind projects, including how they can best be &nbsp;anticipated and mitigated to avoid or manage disputes between developers and contractors. <a href="https://uk.linkedin.com/in/george-fisher-a8b26b72">George Fisher</a> is a senior contentious construction solicitor at SSE Renewables and <a href="https://www.linkedin.com/in/kia-hua-tan-623886155/">Kia Hua Tan</a> is a senior legal counsel at Seatrium Limited.
The trio considers the unique nuances and curve balls that can hamper wind projects, including &nbsp;tight margins and split procurements driving complex interface risks. As the discussion makes clear, careful and precise planning is required to allow for things like extreme weather, vessel availability and rising offshore logistics costs.
On cost volatility, both our guests stress the importance of clarity in fixed-price contracts and price escalation mechanisms to avoid surprises later on. They also flag quality issues across package boundaries, suggesting that these require detailed interface matrices and harmonised dispute provisions to avoid protracted blame games between contractors.
To listen to this and subscribe to future episodes in the Caught In The Crosswinds mini-series, search for &ldquo;Ashurst Legal Outlook&rdquo; on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at <a href="https://www.ashurst.com/podcasts">ashurst.com/podcasts</a>.
To learn more about the issues raised in this episode, <a href="https://www.ashurst.com/en/insights/caught-in-the-crosswinds-navigating-the-surge-in-wind-energy-disputes-part-ii-construction-disputes/">read this article on the Ashurst website</a>.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

The construction phase of wind projects can be fraught with time, cost and quality issues. In this episode, we speak with two industry insiders about some of the common pinch points in the construction of a wind project and explore steps that help minimise the likelihood of contractor/developer disputes occurring.

2. Caught in the Crosswinds – Anticipating (and alleviating) construction pinch points

Cyber readiness is rocketing up the agenda for boards in 2026. We explore cyber readiness including new regulatory developments, trends in cyber threats, and practical defences against attacks.

In this episode of our UK Governance & Compliance mini-series, we explore cyber readiness as one of the top risk-related priorities for boards in 2026. We look at the sobering costs of large disruptions —noting the cause is often small-scale security lapses. We explore the changing cyber landscape including the UK’s expanding Cyber Resilience Bill and the shift to operational disruption as the primary threat. Plus, we provide practical guidance for boards.

Podcast host Will Chalk is joined by John Macpherson, an Ashurst risk advisory partner in Sydney. Also joining the conversation are London colleagues Rhiannon Webster, a partner in Ashurst’s digital economy transactions practice, who heads up the UK cyber response and data protection team, and Matt Worsfold, a partner in Ashurst’s risk advisory team.

To listen to this and subscribe to future episodes in our governance mini-series, search for “Ashurst Legal Outlook” on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at ashurst.com/podcasts.

To receive updates and alerts on the issues raised in this podcast mini-series, subscribe to Ashurst’s regular Governance and Compliance Updates. Read more about the recent AGC Conference here. And read our latest update here about Narrative and Financial Reporting, and Economic Crime and Corporate Transparency.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

Cyber readiness is rocketing up the agenda for boards in 2026. We explore cyber readiness including new regulatory developments, trends in cyber threats, and practical defences against attacks.
In this episode of our UK Governance &amp; Compliance mini-series, we explore cyber readiness as one of the top risk-related priorities for boards in 2026. We look at the sobering costs of large disruptions &mdash;noting the cause is often small-scale security lapses. We explore the changing cyber landscape including the UK&rsquo;s expanding Cyber Resilience Bill and the shift to operational disruption as the primary threat. Plus, we provide practical guidance for boards.
Podcast host <a href="https://www.ashurst.com/en/people/will-chalk/">Will Chalk</a> is joined by <a href="https://www.ashurst.com/en/people/john-macpherson/">John Macpherson</a>, an Ashurst risk advisory partner in Sydney. Also joining the conversation are London colleagues <a href="https://www.ashurst.com/en/people/rhiannon-webster/">Rhiannon Webster</a>, a partner in Ashurst&rsquo;s digital economy transactions practice, who heads up the UK cyber response and data protection team, and <a href="https://www.ashurst.com/en/people/matthew-worsfold/">Matt Worsfold</a>, a partner in Ashurst&rsquo;s risk advisory team.
To listen to this and subscribe to future episodes in our governance mini-series, search for &ldquo;Ashurst Legal Outlook&rdquo; on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at <a href="https://www.ashurst.com/podcasts">ashurst.com/podcasts</a>.
To receive updates and alerts on the issues raised in this podcast mini-series, subscribe to Ashurst&rsquo;s regular <a href="https://www.ashurst.com/en/insights/ashurst-governance-and-compliance-update-issue-66/">Governance and Compliance Updates</a>. Read more about the recent AGC Conference here. And <a href="https://www.ashurst.com/en/insights/agc-issue-74/">read our latest update here about Narrative and Financial Reporting, and Economic Crime and Corporate Transparency.</a>
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

 Cyber readiness is rocketing up the agenda for boards in 2026. We explore cyber readiness including new regulatory developments, trends in cyber threats, and practical defences against attacks.

Governance & Compliance: The changing nature of cyberattacks and cyber regulation

In this opening episode of Ashurst’s Taxed Out series, partners Vanja Podinic and Colin Little unpack the dominant Australian tax controversy themes from 2025 and what they signal for the year ahead. They explore the ATO’s whole-of-code approach, the escalation of scrutiny on financing and marketing hubs, related-party arrangements and private capital, and the continued interplay between transfer pricing, PE risk, intangibles and anti-avoidance.

Colin and Vanja break down the ATO’s FY25 settlement and certainty data, including the decline in APAs, the rise of bilateral agreements, and growing use of the Mutual Agreement Procedure. They also reflect on the landmark decisions that shaped 2025 from embedded royalties and anti-avoidance in PepsiCo and Hicks, to Division 855 disputes in YTL and Newmont, and the Bendel decision now before the High Court.

Finally they close with the 2026 cases to watch, including Bendel, Tabcorp, Coca-Cola and The Star, and share practical steps for taxpayers preparing for another active year of reviews, audits and litigation.

To follow the series, visit ashurst.com or search for Ashurst Legal Outlook on your preferred podcast platform.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

In this opening episode of Ashurst&rsquo;s Taxed Out series, partners <a href="https://www.ashurst.com/en/people/vanja-podinic/">Vanja Podinic</a> and <a href="https://www.ashurst.com/en/people/colin-little/">Colin Little</a> unpack the dominant Australian tax controversy themes from 2025 and what they signal for the year ahead. They explore the ATO&rsquo;s whole-of-code approach, the escalation of scrutiny on financing and marketing hubs, related-party arrangements and private capital, and the continued interplay between transfer pricing, PE risk, intangibles and anti-avoidance.
Colin and Vanja break down the ATO&rsquo;s FY25 settlement and certainty data, including the decline in APAs, the rise of bilateral agreements, and growing use of the Mutual Agreement Procedure. They also reflect on the landmark decisions that shaped 2025 from embedded royalties and anti-avoidance in PepsiCo and Hicks, to Division 855 disputes in YTL and Newmont, and the Bendel decision now before the High Court.
Finally they close with the 2026 cases to watch, including Bendel, Tabcorp, Coca-Cola and The Star, and share practical steps for taxpayers preparing for another active year of reviews, audits and litigation.
To follow the series, visit <a href="https://www.ashurst.com/en/insights/2026/jan/tax-controversy-and-tax-dispute-resolution">ashurst.com</a> or search for Ashurst Legal Outlook on your preferred podcast platform.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

A year of reviews, high-stakes litigation and shifting certainty programs across Australian tax law has left taxpayers recalibrating for 2026. What should businesses expect next?

Taxed Out: How and why data centres are becoming a global tax flashpoint

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