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As most of the Base Erosion and Profit Shifting (BEPS) Action Plan is made up of best practice recommendations rather than ‘red line’ requirements, it was always going to be applied electively and in different ways from country to country.

An active deal environment is a vital ingredient for a vibrant economy and an essential growth driver for many businesses. At the heart of every acquisition of an unlisted entity is a Sale and Purchase Agreement (SPA) that defines both the terms of the transaction and the basis for deriving the final purchase consideration.