Expert in buy- and sell-side deal structuring advisory and tax due diligence
Singapore
@alvarezmarsal
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Darryl Kinneally is a Managing Director with Alvarez & Marsal Tax APAC in Singapore. He specializes in M&A tax.
With more than 30 years of international tax experience, Mr. Kinneally primarily advises on deal structuring and conducts buy- and sell-side tax due diligence. He has worked on a vast number of deals across various APAC markets with extensive experience in Singapore, Indonesia, the Philippines and Vietnam.
Mr. Kinneally's notable assignments include advising a ride hailing company with its acquisition of a competitor operating in 10 ASEAN markets. He has also advised private equity funds with respect to transactions across a wide range of sectors and geographies, including healthcare, technology, infrastructure, renewables, property and education.
Prior to joining A&M, Mr. Kinneally was the lead Partner in EY’s Singapore Transaction Tax practice and their ASEAN Private Equity tax practice for over 10 years. He also spent five years in-house with a Hong Kong, SAR-based company, actively participating in numerous transactions.
Mr. Kinneally earned a bachelor’s degree in commerce from the University of Queensland. He is a member of the Australian & New Zealand Chartered Accountants and the Taxation Institute of Australia and is a Singapore Chartered Tax Professional. Additionally, he has served on the Board of Commissioners of Indofood, Indonesia’s largest food company, as well as an OTC pharmaceutical business in Indonesia.
Deputy Prime Minister and Finance Minister, Mr. Lawrence Wong delivered the 2024 Budget Statement on 16 February 2024. The Budget, themed building our shared future together, is a budget to keep Singapore competitive and moving forward, equip our people to realise their fullest potential and give more assurance to Singaporean families and seniors.
On 14 June 2024, the Inland Revenue Authority of Singapore (IRAS) released the 7th Edition Singapore Transfer Pricing Guidelines, which has introduced changes to the treatment of domestic loans.
In many M&A share transactions, tax losses may represent significant hidden value. But that value depends particularly on two key questions: Can the tax losses survive the transaction and can the parties mutually agree on a business plan substantiating the future usage of the potentially surviving tax losses? Our article outlines how jurisdiction-specific rules — especially Germany’s strict change-in-ownership regime — affect the usability of tax losses post-closing, whether tax losses can provide a shelter for historic tax risks and why tax losses impact purchase price negotiations.
