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  • Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Canada Dominica Entered into force January 10 2012 Tax Information Exchange Agreement Isle of Man Portugal Entered into force January 18 2012 Tax Information Exchange Agreement Bahamas Malta January 18 2012
  • The Supreme Court’s Vodafone judgment is a momentous decision not only for India but also for a large number of foreign investors anxious to be a part of India’s growth story.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $7.3 billion SMFG RBS Aviation Milbank Tweed Clifford Chance Acquisition $3.16 billion Pembina Pipeline Provident Energy Blake, Cassels & Graydon / Paul, Weiss, Rifkind, Wharton & Garrison Norton Rose Canada / Dorsey and Whitney Acquisition $2.85 billion Apache Cordillera Energy Partners III Jefferies & Co / Thompson & Knight Tudor, Pickering, Holt & Co Merger $2.2 billion Abacus Property Group Abacus Storage Fund Freehills Freehills Acquisition $1.46 billion Cinven CPA (Intermediate Capital Group) Freshfields Bruckhaus Deringer DLA Piper Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Rights Offering $473.2 million China Communications Services CITIC Securities Freshfields Bruckhaus Deringer / Jingtian & Gongcheng Davis Polk & Wardwell High Yield Bond Offering $420 million Ardagh Shearman & Sterling - Jeffrey Tate & Craig Gibian Convertible Notes Offering $250 million PHH Corporation JP Morgan / Merrill Lynch / Pierce Fenner & Smith Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Po Sit & Nicole Field
  • With last week’s victory for Vodafone, a message has been sent out to governments around the world that pursuing the taxation of the indirect transfer of shares is an unsustainable policy. But China won’t listen.
  • The Supreme Court’s Vodafone judgment is a momentous decision not only for India but also for a large number of foreign investors anxious to be a part of India’s growth story.
  • With last week’s victory for Vodafone, a message has been sent out to governments around the world that pursuing the taxation of the indirect transfer of shares is an unsustainable policy. But China won’t listen.
  • On January 12 2012, Advocate General Trestenjak’s Opinion in Case C-591/10 Littlewoods Retail Ltd and Others was published. This represents the next phase in the VAT compound interest journey. Should the Court of Justice of the European Union (CJEU) to follow the Advocate General’s Opinion in its judgment, it is very unlikely that this trip to Luxembourg will be the end of the road, argue Michael Anderson and Robert Waterson of Dorsey & Whitney.
  • The Alternative Investment Management Association (AIMA) believes the European Commission’s proposed financial transactions tax (FTT) could lead to a significant decrease in cross-border trading of financial instruments. But there are some who think this is exactly why the EU needs one.
  • France is pressing ahead with what it is calling a social VAT to reduce labour costs and stimulate jobs, but it could end up producing bigger headaches for companies.
  • Some large US multinational companies reported their annual and quarterly results this week, including details of their effective tax rates.