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  • Shinzo Abe, Japan’s Prime Minister, remains committed to reducing the corporate tax rate in the country, despite objections from senior figures in his Liberal Democratic Party (LDP).
  • The OECD’s work on base erosion and profit shifting (BEPS) is in the spotlight of worldwide taxation. Based on the Action Plan from last July and on two other reports – one published in March 2012 entitled Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues and the other in February 2013 entitled Addressing Base Erosion and Profit Shifting – the OECD is clearly emphasising the need for action on this issue.
  • On September 8, the President of Mexico, Enrique Peña Nieto, submitted to the Congress, the Bill for the Tax Reform for 2014. This bill has been highly expected by the business community and taxpayers, explain Sara Lucía Romero and Gustavo Gómez of EY.
  • Svitlana Musienko and Dmytro Donets, of DLA Piper Ukraine, analyse the approach of the Ukrainian courts in transfer pricing disputes.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.28 billion Packaging Corporation of America Boise Mayer Brown Skadden, Arps, Slate, Meagher & Flom Acquisition $1.1 billion Huntsman Rockwood (Performance Additives and Titanium Dioxide) Vinson & Elkins Hughes Hubbard & Reed / Willkie Farr & Gallagher Acquisition $607 million Ultratech Jaypee Cement (Gujarat Unit) Amarchand & Mangaldas Bansi S Mehta & Co Acquisition / Joint Venture $300 million Clayton, Dubilier & Rice Harsco / Brand Energy & Infrastructure Services Debevoise & Plimpton Weil, Gotshal & Manges Acquisition $150.9 million Shanxi Donghui Coal Coking & Chemical Group Inova Resources Stikeman Elliott Acquisition Undisclosed Appirio TopCoder Fenwick & West - Ron Schrotenboer, Amanda Athanasiou Merger Undisclosed Mindjet Spigit Fenwick & West Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Secondary Offering $937 million NXP Semiconductors Morgan Stanley Simpson Thacher & Bartlett Davis Polk & Wardwell - John Paton Common Stock Offering $122.2 million Kennedy-Wilson Holdings Deutsche Bank Latham & Watkins / Kulik, Gottesman & Siegel Davis Polk & Wardwell - Michael Farber
  • Commission investigates Ireland, Luxembourg, Netherlands; Mexican tax reform; BMC Software Tax Court defeat; Australian deduction uncertainty; Partnerships in VAT groups; EU FTT; IRS corrects FATCA regulations; and Swiss Parliament votes for FATCA.
  • Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Guernsey Hungary September 11 2013 Tax Information Exchange Agreement Guernsey Switzerland September 11 2013 Double Taxation Avoidance Agreement (Protocol) Bahrain China September 16 2013 Tax Information Exchange Agreement Jersey Switzerland September 16 2013 Tax Information Exchange Agreement Isle of Man Italy September 17 2013 Tax Information Exchange Agreement Isle of Man Lesotho September 17 2013 Double Taxation Avoidance Agreement India Latvia September 18 2013
  • Panellists on the controversy panel at International Tax Review’s 13th Global Transfer Pricing Forum in New York this week said it is crucial to find out which IRS tax officials will be involved in your transfer pricing audit process.
  • Despite the OECD’s Base Erosion and Profit Shifting (BEPS) project being much broader than the intangibles project in terms of its impact on corporate tax, the time frame for the BEPS is much shorter and there is more pressure for the working group to provide guidance.
  • Stewart Grieve, a partner of Corrs Chambers Westgarth in Melbourne, explains why the Federal Court of Australia’s ruling in the SPI PowerNet case highlights the uncertainty taxpayers face when applying the general deduction provision.