Editorial

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

Welcome to International Tax Review's M&A guide 2017. Transactional work is the bread and butter for many tax practices, and the market has bounced back strongly to near its pre-financial crisis levels, with 2016 being the third consecutive year in which overall transactional volume surpassed $2.5 billion.

However, 2016 was quieter than the record-breaking year of 2015. The overall number of deals worth more than $10 billion was around 35% lower than 2015, with the average deal size also lower at $115.4 million, but 'mega deals' such as the purchase of Time Warner by AT&T, Bayer's $66 billion purchase of Monsanto and the $52 billion merger between Sunoco Logistics Partners and Energy Transfer Partners. Qualcomm's purchase of NXP Semiconductors for around $47 billion became the largest semiconductor deal on record.

Moving into 2017, British American Tobacco's $49 billion deal to acquire the 57.8% of Reynolds Tobacco, which it did not already own, got the year off to a strong start when the deal was finally closed in January. The transaction made BAT the world's largest listed tobacco company.

However, while the market has picked up in recent years, the OECD's BEPS Project has brought new layers of complexity for taxpayers and their advisers to consider.

Permanent establishment (PE) is a key consideration in many of the jurisdictions covered in the M&A guide, as is the concept of state aid in the EU and surrounding countries. The UK's exit from the European Union has created shockwaves around the world, particularly in the UK itself and the EU, and the election of Donald Trump has thrown the long-awaited US tax reform into uncertainty, as companies are left to speculate on what form the new system will take.

There are also a multitude of domestic tax law changes, some influenced by BEPS, which are examined in the pages of this guide. I hope that you will find it informative to your decision-making when carrying out deals in the coming year.

Joe Stanley-Smith

Deputy editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

As ITR data reveals that 2025 saw more than double the amount of private client hires than 2024, it seems firms are jostling for position
The US multinational paid 20% more tax in 2025 than 2024, it said; in other news, more than 25,000 HMRC staff have been upskilled on AI
Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
The acquisition of a two-partner practice from Stephenson Harwood means that Charles Russell Speechlys has the largest private client team in Asia, the firm claimed
Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
Gift this article