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

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
Gift this article