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Team Members

Murray Shume

Special Counsel
Murray assists a broad range of clients facing issues involving revenue authorities, with specialised experience in dealing with the ATO and the OSR.

As a special counsel in our commercial group, Murray works in resolving tax disputes as well as providing advice on a broad range of income tax and indirect tax issues.

Murray specialises in income tax (including international tax, asset betterment cases and residency issues), capital gains tax (including the taxation of compensation payments in the mining and gas industry), employee share schemes, non-commercial losses, GST and payroll tax.

His experience includes drafting notices of objections and private ruling applications. He regularly acts for clients in tax related AAT appeals and litigation in the Federal Court.

Murray has acted for the taxpayers in Hacon Pty Ltd and Ors v Commissioner of Taxation [2017] FCA 659, Shadforth Lythgo Pty Ltd v Commissioner of State Revenue GAR098-15, Dempsey v Commissioner of Taxation [2014] AATA 335 (residency) and Dominic B Fishing Pty Ltd v Commissioner of Taxation [2014] AATA 205 (superannuation guarantee charge case), and has also settled many disputes before hearing.

Before joining CGW in 2012, Murray worked at the ATO specialising in CGT and international taxation.

This experience has given Murray a unique perspective on dealing with the ATO during any dispute.

  • Diploma of Law (LPAB)
  • Graduate Diploma of Legal Practice – The College of Law
  • Solicitor – Supreme Court of Queensland
  • Acted for the successful taxpayer in:
    • Hacon Pty Ltd and Ors v Commissioner of Taxation [2017] FCA 659, by having the ATO’s decision to decline to make a private ruling quashed in a judicial review (currently on appeal to the Full Federal Court)
    • Shadforth Lythgo Pty Ltd v Commissioner of State Revenue GAR098-15, where QCAT accepted that the client should be de-grouped for payroll tax purposes
    • Dempsey and Commissioner of Taxation [2014] AATA 335 by proving the client was not a resident of Australia for income tax purposes
    • Dominic B Fishing Pty Ltd v Commissioner of Taxation [2014] AATA 205 by proving that there was there was no employment relationship between the client and fishermen.
  • Recently settled appeals in the taxpayer’s favour on issues relating to residency and non-commercial losses.
  • Negotiated settlements with the ATO in the course of income tax audits and objections.
  • Successfully objected to ATO assessments on various tax and penalty issues.
  • Assisted clients in applying for remission of general interest charge (GIC).
  • Advised on complex income tax and GST issues for inbound investments into Australia.
  • Currently co-editor of the Australian chapter of the Bloomberg BNA VAT Navigator.



  • ‘Forming and opinion of “fraud or evasion” – is this the Commissioner’s unchallengeable right to an unlimited amendment period? Australian Tax Law Bulletin 2017 Vol 4 No 1
  • ‘Uber, Airbnb, Netflix … Australia’s steps to Tax the Sharing and Digital Economies’ Tax Planning International Indirect Taxes Vol 13, No 7, July 2015, Bloomberg BNA
  • ‘ESS Plans for start-up companies’, July 2015, Tax Institute of Australia

Areas of Expertise


It Depends - I have received a Director Penalty Notice, what are my options?

In this edition of ‘It depends’, lawyer Jack Colley talks about director penalty notices (DPNs). Jack explains what DPNs are, the difference between lockdown and non-lockdown DPNs and what your options are if you receive one from the ATO.

Can businesses reduce the risk of incorrectly classifying workers as employees or contractors?

Correctly distinguishing between employees and contractors is critical for businesses, with significant consequences for incorrectly applying the law. The case law has developed rapidly in this space in the last couple of years. Those cases provide some helpful lessons for businesses seeking to reduce their risks when contracting with sole traders.

Potential payroll tax amnesty for GPs, but no dice for other medical and allied health professionals

The Queensland Revenue Office (QRO) is calling for medical centres who contract with general practitioners (GPs) to complete an expression of interest form by 30 June 2023 if they want to apply for an amnesty in respect of any payroll tax liabilities on payments made to GPs between the 2018 and 2025 income years.