Developing countries have been concerned that offshore indirect transfers can be used to avoid capital gains taxation in the country where the underlying assets are located. Famous tax controversies include the Vodafone case in India, acquisition of Petrotech in Peru, acquisition of Minera Disputada Las Condes by Anglo American in Chile and the Zain case in Uganda. Several countries, including Argentina, Brazil, Chile, India and Peru, have implemented rules for taxation of indirect transfers or challenging transactions reputed as abusive tax planning. This panel will discuss the impact of taxation of indirect transfers on global M&A transactions, including issues around thresholds for triggering tax in the source country, valuation of underlying assets, rules on real estate thresholds, attribution of capital gains, interface of indirect transfer rules with tax treaties and enforcement rules to collect tax liability.