Editorial

The world's M&A market remains as chaotic as ever. That is not to say it is all bad news for deal makers. Big money transactions, such as the proposed $24 billion Dell buyout, the $23 billion Heinz acquisition by an investor group led by Warren Buffett's Berkshire Hathaway, and, though it has met some official resistance, Anheuser-Busch InBev's $20 billion takeover of Mexican brewer Grupo Modelo, suggest the market is slowly beginning to pick up in North America.

The Latin American M&A market, meanwhile, is actually benefiting from the sluggishness of Europe and the US, with China increasingly looking to invest in this dynamic region. And because of the market's growth, acquirers appear more likely to accept risks than they were in the past.

Asia is more of a mixed story. It includes some of the world's most prominent tax havens, such as Hong Kong and Singapore, which are seeking to maintain their attractiveness as holding company locations by offering tax benefits. Meanwhile the bigger players such as India, China and Australia are increasingly looking to crack down on tax avoidance in M&A transactions.

In Europe, meanwhile, tax directors are concerned about potential complexity arising from a common consolidated corporate tax base (CCCTB) in the EU, if a subsidiary of a group in the CCCTB zone becomes a subsidiary of a group outside it or vice versa.

The articles in this year's Mergers & Acquisitions supplement reflect the divergent trends in the global M&A market and how tax legislation in different countries is helping companies in some cases, while hindering them in others.

Brazil, for example, is becoming an increasingly attractive location for foreign investment. But Ernst & Young Terco argues that the complexity of its tax system is presenting challenges for businesses.

PwC, on the other hand, makes the case that Mexico is really where taxpayers should be thinking about investing.

Cyprus, meanwhile, has suffered heavily from the financial downturn. M&A takes on a special significance in such difficult times, explains Eurofast Taxand.

Switzerland is always high on lists of business-friendly investment locations, but it is also high on the list of jurisdictions attracting criticism for eroding the tax bases of other countries. With tax reform on the agenda, burckhardt discusses its vision of how Switzerland could keep all parties happy.

These articles and more show that though there are signs of recovery, the M&A market is turbulent and will remain so for the foreseeable future.

Salman Shaheen

Editor

International Tax Review