In structuring an international acquisition, it is necessary to consider income tax issues in three sets of jurisdictions. These are:
- the jurisdictions of the companies whose shares or assets will be acquired,
- the intermediary jurisdictions, which may be used as hosts for holding companies or financing structures, and
- the tax regime in the parent company's home country.
To consider any one of these alone can result in unexpected and adverse tax consequences at worst, or a sub-optimized structure at best.
ITSG members are highly experienced in coordinating international acquisitions, be they simple or highly complex, of modest size or extremely large, public or private, asset purchasers, share arrangements, or hybrid combinations.
Since ITSG members have evolved a relationship of working closely with one another, through our experience, we have developed various approaches to structuring acquisitions in major financial centres around the world. A combination of local knowledge and international experience provide a solid foundation for the development of an optimum acquisition structure.
In addition, when necessary, ITSG members can provide expertise in the customs duty, VAT, or sales tax, particularly in the European Union, North America, and the Far East.