Current trends in international taxation are focused on the taxation of business income in general, and not on the treatment of gain or loss from acquisitions.

Their focus on substance is likely to change the way acquisitions are structured, however. Incentives for entities to proliferate on the buy side will be reduced by mandatory consolidation, by measures designed to ensure income is taxed in the jurisdiction where income-producing activities are carried out, and provisions to constrain the benefits of preferential tax regimes.