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  • The amended Decree from the Ministry of Finance on the methods and procedures of determining taxable income, by estimating prices and the methods and procedures of eliminating double taxation in the case of a transfer pricing adjustment (TP regulation), was implemented on July 18.
  • Fabrizio Lolliri, European director of transfer pricing at Hogan Lovells, and Catherine Clare, international tax manager at Tate & Lyle, a UK-based multinational agribusiness, explain how to make the most of your relationship with your transfer pricing adviser and how to review and set new transfer pricing policies, in the context of a large multinational enterprise.
  • The French tax authorities are likely to step up their scrutiny of so-called non-cooperative states and territories (NCST) in the future. International groups and private-equity funds should examine their structures to see if any measures related to this year’s list of such jurisdictions will affect them.
  • A change in the final version of a document critical to compliance with the Foreign Account Tax Compliance Act (FATCA) will allow financial firms to choose which form of due diligence procedures to follow.
  • Italy’s parliament has passed the Google tax which will require companies to buy internet advertisements from locally-registered companies and not from companies based in tax havens including Bermuda and Ireland. But the proposal may violate EU laws on non-discrimination regarding commercial activity.
  • Progress towards reforming the US tax code will be delayed even further now that Max Baucus, the Montana Democrat who chairs the Senate Finance Committee, is moving to Beijing to take up his new role as US ambassador to China.
  • A number of large VAT rises rang in the New Year, but there are signs the rate of VAT rises is slowing in the more developed economies.
  • The Portuguese corporate income tax (CIT) reform - approved in the last days of December - has the following four cornerstones: simplification, competitiveness, decrease of CIT rate and review of existing tax incentives or preferences. The new rules will be applicable to tax periods starting, or taxable events occurring, on or after January 1 2014.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.65 billion NCR Corporation Digital Insight Womble Carlyle Sandridge & Rice Acquisition $374 million Seagate Technology Xyratex Wilson Sonsini Goodrich & Rosati Latham & Watkins - Samuel Weiner Acquisition Undisclosed Stern Partners McRae Environmental Services Stikeman Elliott Repurchase Undisclosed JMC Steel Group Carlyle Partners; CP IV Coinvestment Stikeman Elliott Latham & Watkins Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Acquisition financing $4.1 billion Tribune Company JP Morgan Securities; Citigroup Global Markets; Deutsche Bank; Credit Suisse; Barclays; Goldman Sachs; UBS Debevoise & Plimpton Wiley Rein; Davis Polk & Wardwell - Michael Farber, Adam Perry Acquisition financing $2.7 billion Fidelity National Financial Merrill Lynch, Pierce, Fenner & Smith; JP Morgan Securities Weil, Gotshal & Manges Davis Polk & Wardwell Notes offering $2.25 billion Devon Energy Corporation JP Morgan Stanley; Barclays Capital; Goldman Sachs Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Lucy Farr; Juelle Gomes Acquisition financing $1.2 billion Textron Inc JP Morgan Securities Gibson, Dunn & Crutcher Davis Polk & Wardwell Corporate Tender Offer $850 million Apache JP Morgan Securities; RBS Securities; Citigroup Global Markets Bracewell & Giuliani Davis Polk & Wardwell - Harry Ballan, Ankur Dalal Convertible senior notes offering $220 million TTM Technologies JP Morgan Securities; RBS Securities Davis Polk & Wardwell - Rachel Kleinberg, Catherine Paskoff Chang Senior secured notes offering $200 million Roundy's Supermarkets Credit Suisse Securities; JP Morgan Securities Davis Polk & Wardwell - Gregory Hannibal, Adam Bedzow Acquisition financing Undisclosed Albain Bidco Norway Altor Equity Partners; Bain Capital Kirkland & Ellis; Stikeman Elliott - Frank Mathieu Cravath, Swaine & Moore; Linklaters; Borden Ladner
  • Ajit Tolani has left Economic Laws Practice in Mumbai to set up his own tax, transfer pricing and international tax litigation practice called Ajit R Tolani. As well as appearing as tax and transfer pricing counsel in litigation throughout India, he will advise clients on all direct tax issues, domestic and international transfer pricing, and draft appeals for various tax forums.