Billion-dollar charity locked in $923m tax fight with the ATO

His gardener and receptionist became millionaires overnight. His best friend and “right hand” man received $400 million.But the greatest beneficiary of Paul Ramsay’s will was his charity.Paul Ramsay died in 2014, leaving a fortune of more than $3.5 billion.Now, more than a decade after the private healthcare pioneer’s sudden death, the Paul Ramsay Foundation is locked in a $923 million fight with the Australian Taxation Office over income tax.Headquartered in a sandstone building with elaborate forged-steel gates in Sydney’s Darlinghurst, the foundation funds university research, Indigenous ventures and anti-poverty initiatives.It also underpins the Ramsay Centre for Western Civilisation, a separate and at times contentious humanities program that champions a Western canon and values. The centre, whose board includes former prime minister Tony Abbott, received $37 million from the foundation in 2024-2025.The Darlinghurst headquarters of the Paul Ramsay Foundation.Louise KennerleyThe tax fight, according to financial accounts submitted to the charities watchdog, stems from “legacy matters arising from the administration of the estate of the late Paul Ramsay”.Single, and with no children, Ramsay was worth about $3.5 billion when he succumbed to a suspected heart attack while sailing in Spain, aged 78.His fortune came from the private hospital empire he had built over decades, starting with an old guesthouse on Sydney’s north shore, which he converted into a psychiatric facility in 1964.Ramsay Healthcare today trades publicly at a valuation of nearly $10 billion, operating across Australia, the United Kingdom and Europe.After the founder’s death, ownership of shares he owned in the company was transferred to a private ancillary fund – a vehicle often used by the wealthy to bankroll charitable ventures – as part of a $3 billion bequest to the foundation.The Ramsay fund is at the centre of the dispute with the tax office, which conducted an income tax audit for the years 2016, 2017 and 2018.“The total primary tax amount levied on the [fund] is $699 million,” the charity wrote in its annual accounts, which also referred to a $175 million penalty and $49 million in interest charges.The fund objects to the income tax assessments. If unsuccessful, the Paul Ramsay Foundation will foot the bill.A foundation spokesman said the tax audit focused on steps taken in 2016 to administer Ramsay’s estate after he “died unexpectedly”.“The steps were taken with the benefit of tax advice from a leading accounting firm, as well as independent legal advice,” the spokesman said. He said the dispute did not relate to the foundation’s “charitable purpose or operations” and “does not impact the charity’s funding partners”.Those partners include the NSW National Parks and Wildlife Service, the University of Newcastle, RMIT, The Royal Women’s Hospital in Melbourne, the Queensland Performing Arts Trust, The Australia Institute and The Smith Family.The foundation says it has distributed “more than $1.5 billion in funding to charities seeking to address disadvantage in Australia” since 2017.But the value of its assets has declined with falls in Ramsay Healthcare’s share price. A foundation subsidiary has sold shares in recent years to meet “cashflow needs”.A tax office spokesperson declined to comment, citing “obligations under taxpayer confidentiality laws”.Start the day with a summary of the day’s most important and interesting stories, analysis and insights. Sign up for our Morning Edition newsletter.More:PhilanthropyRamsay Health CarePaul RamsayRamsay CentreCharityInvestigationFrom our partners