Tax Planning for International Mergers, Acquisitions, Joint Ventures, and Restructurings, 2nd Edition

This market leading resource is an essential guide for international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.

Tax Planning for International Mergers, Acquisitions, Joint Ventures, and Restructurings will help the practitioner to:

• Develop a working knowledge of the salient aspects of the relevant law across a broad range of global jurisdictions with the unique mixture of context and actionable guidance
• Adapt to changing market conditions and client’s needs with comprehensive expert guidance on international tax aspects of both expansion and contraction
• Confidently maximise global market opportunities with practical solutions designed to maximise effective tax planning and compliance, whilst minimizing risks and reducing costs
• Optimise the decision making process in key areas such as due diligence, capital raising, securitization and tax efficient structuring of deals. Planning checklists layout key criteria to aid efficient implementation

Tax Planning for International Mergers, Acquisitions, Joint Ventures, and Restructurings is an incomparable resource offering:

• Market leading coverage of the complex tax aspects of international expansion and contraction
• Holistic approach to tax planning that combines the legal parameters with compliance realities and planning opportunities
• Unique detailed country profiles written by local expert authors that highlight key areas of concern and discuss the implementation of potential solutions
• Practical guidance to support the assessment, strategizing and implementation of international transactions

The work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick comparison of key tax aspects in major jurisdictions. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.

This user-friendly resource is comprised of two complementary parts: first, a practical overview of certain key tax aspects of international transactions that have general application, followed by twenty-one detailed country profiles, pinpointing each jurisdiction’s handling of such areas of concern as entity classification, taxable transactions, tax-free transactions (both domestically and cross-border), loss planning, IP planning, compensation arrangements, acquisition financing, JV planning, VAT issues, tax treaty usage, and much more. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations.

The work will assist in planning and evaluating strategies for transactions in single and multiple jurisdictions, as well as in implementing them. It further will allow an easy comparison of key tax aspects in major jurisdictions. Addressing an important information gap in an area of widespread commercial concern, this resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.

This publication consists of two volumes.

Each country profile follows the same structure to allow for fast identification of the key aspects of each tax regime and efficient comparison of critical subject specific data: 

• Introduction
• Taxable Acquisitions and Dispositions
• Tax-free Acquisitions and Dispositions
• Attribute Preservation and Usage
• Due Diligence and Contractual Tax Protection
• Financing and Debt Pushdown Strategies
• Dealing with Compensation Plans
• Grouping
• Planning with Intangibles
• Internal Restructuring Involving Target
• Target Breakup or Other Disposition of Unwanted Assets
• Demergers
• Subsidiary Liquidations
• Joint Ventures
• Equity and Debt Restructuring
• Corporate Expatriations
• Business Restructuring
• Corporation as Acquisition Vehicle for Foreign Target