Editorial

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

Welcome to International Tax Review's M&A guide 2017. Transactional work is the bread and butter for many tax practices, and the market has bounced back strongly to near its pre-financial crisis levels, with 2016 being the third consecutive year in which overall transactional volume surpassed $2.5 billion.

However, 2016 was quieter than the record-breaking year of 2015. The overall number of deals worth more than $10 billion was around 35% lower than 2015, with the average deal size also lower at $115.4 million, but 'mega deals' such as the purchase of Time Warner by AT&T, Bayer's $66 billion purchase of Monsanto and the $52 billion merger between Sunoco Logistics Partners and Energy Transfer Partners. Qualcomm's purchase of NXP Semiconductors for around $47 billion became the largest semiconductor deal on record.

Moving into 2017, British American Tobacco's $49 billion deal to acquire the 57.8% of Reynolds Tobacco, which it did not already own, got the year off to a strong start when the deal was finally closed in January. The transaction made BAT the world's largest listed tobacco company.

However, while the market has picked up in recent years, the OECD's BEPS Project has brought new layers of complexity for taxpayers and their advisers to consider.

Permanent establishment (PE) is a key consideration in many of the jurisdictions covered in the M&A guide, as is the concept of state aid in the EU and surrounding countries. The UK's exit from the European Union has created shockwaves around the world, particularly in the UK itself and the EU, and the election of Donald Trump has thrown the long-awaited US tax reform into uncertainty, as companies are left to speculate on what form the new system will take.

There are also a multitude of domestic tax law changes, some influenced by BEPS, which are examined in the pages of this guide. I hope that you will find it informative to your decision-making when carrying out deals in the coming year.

Joe Stanley-Smith

Deputy editor

International Tax Review

more across site & bottom lb ros

More from across our site

In-house teams who want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
The OECD has vowed to continue working with the US despite the president effectively pulling the country out of the organisation’s global minimum tax deal
Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies
Thomson Reuters now has ‘end-to-end capability’ for its tax workflow business, according to its president for tax accounting and audit professionals
Patrick O’Gara, who is rated as a ‘highly regarded practitioner’ by World Tax, had spent over 20 years at Baker McKenzie
If approved, it would become the first ‘big four’ firm to practise law in the US; in other news, Morrison Foerster hired a new global tax co-chair
The ‘birth date’ of the service, which will collect tariffs, duties and other foreign revenue, will be January 20
Awards
Submit your nominations to this year's WIBL Americas Awards by February 28
Awards
Research for the annual Women in Business Law Awards has begun – submit your entries by February 28
In-house counsel across a number of regions are unimpressed with their tax advisers’ CSR efforts, according to ITR+ research
Gift this article