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  • In recent months, László Pásztor, of PMX Consulting, has seen a rise in the number of communication channels and appearances by associates of the Hungarian tax authority in transfer pricing topics. He discusses recent developments and how taxpayers need to adapt to keep up with the authorities.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger Undisclosed Pfizer Limited Wyeth Limited EY Davis Polk & Wardwell Acquisition Undisclosed Vicente Capital Partners iBwave Solutions Stikeman Elliott - Philippe Kattan, Frank Mathieu Acquisition Undisclosed Dynamic Precision Group (Carlyle Group) Unison Engine Components (8 manufacturing facilities) Latham & Watkins; PwC; Stikeman Elliott - Frank Mathieu Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Convertible senior notes offering $205 million RPM International Wells Fargo; Goldman, Sachs Calfee, Halter & Griswold Davis Polk & Wardwell - Lucy Farr, Ankur Dalal; Squire Sanders Initial public offering $80.5 million Xencor Credit Suisse Securities; Leerink Swann Cooley Davis Polk & Wardwell - Harry Ballan, Catherine Paskoff Chang Common stock offering $46 million Medallion Financial Corporation Morgan Stanley; Keefe, Bruyette & Woods; Sandler O'Neill Davis Polk & Wardwell - Michael Mollerus, Arie Rubenstein, Juelle Gomes
  • Giles Salmond is joining Eversheds in London in the new year as head of the law firm’s VAT disputes and indirect taxes practice.
  • Earlier this week, the US Supreme Court declined Amazon and Overstock’s applications for a hearing in a case relating to a law requiring out-of-state vendors to collect sales tax on New York transactions when they use New York residents to solicit business within the state through websites.
  • Last week’s Vodafone case about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in India. The facts of the case so far - and whether an adjustment under transfer pricing regulations should be applied - are now being considered by advisers and their clients.
  • In a judgment in Nice Cheer Investment Limited FACV 23/2012, the Hong Kong Court of Final Appeal ruled that year-end unrealised revaluation gains from listed securities held for sale were not chargeable to tax in Hong Kong.
  • Patrick Stevens, a past president of the Chartered Institute of Taxation in the UK, has become the organisation’s new tax policy director, in succession to John Whiting, who retired on April 1 to become a non-executive director of HM Revenue & Customs.
  • John Leopardi and Emmanuel Sala, Blake, Cassels & Graydon explain why seller pre-closing debt cleaning transactions are costly to the buyer.
  • George Osborne, UK Chancellor of the Exchequer, today unveiled his Autumn Statement. Anti-avoidance measures dominated, with Osborne promising they will raise £9 billion ($15 billion) over five years.
  • Last week’s Vodafone case at the Bombay High Court about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in India.