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Brendan Brown Debate over tax policy will feature in the run-up to New Zealand's general election to be held on September 20 2014. New Zealand has a parliamentary system of government, under which members of the legislature are elected every three years. The electoral system is a mixed member proportional system, under which a political party's representation in the legislature is intended broadly to reflect the proportion of votes cast nationwide for that party. One consequence of that system is that the party with the highest level of support will not necessarily win government, since other parties may combine to form a coalition government or to support a smaller party in minority government. Further, the policies of smaller parties may have a greater prospect of being implemented than would be the case in a two-party system.

Rajendra Nayak

David Cuellar

Peter Dachs Previously South Africa had separate thin capitalisation rules and a practice note that dealt both with how to calculate the quantum of loan funding to equity (3:1 debt-to-equity ratio) as well as the interest in respect of such loan funding between related parties on a cross-border basis. There are no longer separate thin capitalisation rules and thin capitalisation is now dealt with under the transfer pricing rules. There is a draft interpretation note on thin capitalisation. It should be noted that interpretation notes do not have any binding effect. However, they generally provide an indication of how SARS will treat certain transactions.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $970 million Amazon.com Inc. Twitch Interactive Inc. Fenwick & West Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $500 million XPO Logistics Inc. Credit Suisse Securities (USA) LLC, , Morgan Stanley & Co. LLC, Citigroup Global Markets Inc. and Deutsche Bank Securities Inc. Wachtell Lipton Rosen & Katz Davis Polk & Wardwell - Rachael Kleinberg, Isaac MacDonald Secured Margin Loan $400 million Liberty TripAdvisor J.P. Morgan Chase Bank, N.A., and Credit Suisse AG Baker Botts Davis Polk & Wardwell - Michael Farber, Sam Van Peperstraete

As countries continue their efforts to reform the international tax rules, ITR is gauging in-house tax professionals’ views on the topic. Tell us yours.

Tax professionals are worried about how to identify user participation accurately within any digital business model, particularly given how easy it is for users to hide their true location.

As details emerge of digital taxes in the Czech Republic and Malaysia, corporates told ITR they wish countries would leave it to the OECD process – but they are fearful of what might emerge from it.

Tim Gummer, who joined Ashurst in 2007, has been made partner.

The winners of International Tax Review’s 2019 Asia Tax Awards have been announced.