ITR Search | International Tax Review

Switzerland: Post acquisition measures to reorganise an acquired structure

Rolf Wüthrich of burckhardt discusses the acquisition of a Swiss company with subsequent cross-border emigration or cross-border merger as outbound measures out of Switzerland to another country.

March 20 2014

Hong Kong: Structuring cross-border M&A into Hong Kong surge

Hong Kong is a popular investment destination. Here, Darren Bowdern and Benjamin Pong of KPMG China, look at why this is and assess the provisions taxpayers must be aware of when structuring cross-border M&A transactions into the jurisdiction.

March 20 2014

Colombia: New tax regime for M&A processes in Colombia

New regulations enacted by the Colombian Congress, ending fiscal year 2012, with respect to the tax treatment of M&A processes, must be carefully taken into consideration for both public and private M&A transactions. Martín Acero and Oscar González of prietocarrizosa provide helpful tips for taxpayers.

March 20 2014

M&A and corporate taxpayers in light of the BEPS initiative

Tax planning in M&A transactions starts long before a transaction appears on the horizon and continues long after the deal is completed. Key challenges for the tax function are explored by Christoph Huber and Napoleão Dagnese of OC Oerlikon, a traditional Swiss multi-industries conglomerate with a footprint in 34 countries.

March 20 2014

Germany: BEPS and cross border regulation in Germany

Addressing tax base erosion and profit shifting (BEPS), as well as certain other instruments such as dual loss consolidation, is currently one of the most central points of concern for international tax legislation say Claus Herfort and Alke Fiebig of PwC, particularly for the respective bodies of the EU and the OECD.

March 20 2014

Bharti Airtel decision puts emphasis on transfer pricing principles in guarantee cases

The decision of the Delhi Income Tax Appellate Tribunal (ITAT) in the Bharti Airtel case should encourage other Indian taxpayers to apply commercial and transfer pricing principles to agreements concerning corporate guarantees and capital contributions to associated enterprises in India, practitioners have said.

Ralph Cunningham, March 20 2014

Global: Using tax to enhance exit value on divestments

From the perspective of a divesting group, tax is all too often just viewed as a cost and potential barrier to a successful exit. This is understandable given the often narrow focus on the impact of tax in a divestment but by broadening this perspective there is significant incremental commercial value that can be realised. Richard Clarke and Todd Miller of EY discuss.

March 20 2014

China: China remains the favoured destination for cross-border M&A

John Gu, Paul Ma and Christopher Mak of KPMG China analyse the challenges associated with cross-border M&A transactions in China.

March 20 2014

Mexico: The relevance of the social security due diligence

The social security system of any country must be analysed for taking the best decisions in M&A transactions. Yazmin Caceres and María Dolores Enríquez Medina of PwC explain why this analysis should take into account the legislation, practices and risks that investors may face in Mexico.

March 20 2014

Editorial

The M&A market is looking strong for tax experts in 2014 and taxpayers are expecting to complete more divestitures.

March 20 2014

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