ABSTRACT
No major deal by transnational corporations (TNCs) takes place without consideration of the tax implications and optimal tax arrangements. Indeed, a great many investments and transactions are formulated on the basis of analysis of tax advantages, very often due to anomalies in the interaction of different tax systems, and lawyers play a key part in devising such transactions and financings. The basic patterns and strategies for minimiz ing tax liability of international investments were developed by the large TNCs themselves, and in-house specialists still play a major strategic role in tax planning for such large corporations, using local firms of accountants or lawyers where necessary for tax compliance procedures. However, com petitive pressures caused the increasingly widespread use and availability of facilities for international tax avoidance.
