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The term "international management buyout' could aptly describe several different circumstances. It could mean simply that a group of companies being purchased by a management team has operations in several countries round the world. It could appropriately describe the situation where the management team and investing institutions comprise individuals and corporations resident in different territories. Or perhaps it applies where the management team and the vendor group are in different countries.
Each one of the above would present tax complications in addition to those faced in a conventional "local' management buyout. Where all three sets of circumstances apply at once, the tax complexities can be fairly daunting. To understand the demands of the various parties involved, to identify the problems arising in different jurisdictions, and to provide solutions which optimise the worldwide tax position within the desired commercial framework--all of these require specialist advice, a capacity for detail, an ability to isolate the essential points, and a clear head!
Purchase of assets or shares
As with any buyout, in order to decide whether to purchase assets or shares of the target group, accountants' investigation into the financial position of the existing subsidiaries needs to include an assessment of their local tax position, to determine the availability of tax losses, the tax basis of assets, hidden liabilities, and so on.