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Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $17 billion Pfizer Hospira Ropes & Gray; Clifford Chance Skadden Arps Slate Meagher & Flom Definitive combination agreement $16 billion Rock-Tenn Company MeadWestvaco Blackstone Advisory Partners; Cravath, Swaine & Moore Wachtell, Lipton, Rosen & Katz: Jodi Schwartz, Joshua Holmes, Michael Sabbah; BofA Merill Lynch; Goldman Sachs Merger-of-equals $11 billion PartnerRe AXIS Capital Holdings Davis Polk; Credit Suisse (financial) represented by Skadden Arps Slate Meagher & Flom Simpson Thacher & Bartlett; Conyers Dill & Pearman; Goldman Sachs Acquisition $10.5 billion Frontier Communications Corporation Verizon Communications (wireline operations in California, Florida and Texas) Skadden Arps Slate Meagher & Flom: Steven Matays; Greenhill & Co advised Frontier’s board of directors

Italian firm Pirola has joined Praxity, the world’s largest group of independent accountancy firms, becoming its second Italian firm alongside Mazars.

Maik Thomas Heggmair of WTS discusses recent transfer pricing changes in Germany, including the adoption of the authorised OECD approach (AOA) into German legislation and incoming reporting changes and provides practical views on recent audit experiences.

The private banking unit of HSBC in Switzerland has barely been out of the news over the last month. Details have been revealed of how bank staff were aware they were dealing with tax non-compliant account holders and, in a large number of cases, helped some customers evade taxes. The overriding message here is that banks still have a long way to go on transparency and are doing too little to ensure they and their clients are tax compliant.

Transactions with no direct Chinese element could still be caught under the scope of the new law, for example when one party holds a Chinese branch In a strong indication of its growing commitment to enforcing tax compliance, China's State Administration of Taxation released updated indirect transfer rules to replace Notice 698. Tax professionals say the more stringent tax rules, which include safe harbour regulations, withholding tax obligations of the buyer, and clarifications of reasonable commercial purpose, are both welcome and concerning. Notice 7 is effective from February 3 2015, though applies to transactions from January 1 2008 that have not received an assessment from the tax authorities. China's Notice 698 was introduced in December 2009, but was effective for transactions dating after January 1 2008.

Many business groups view the Obama proposals as out of kilter with the rest of the world President Obama unveiled his FY 2016 Budget plan last month, seeking to replace the existing deferral system for US multinational companies and impose a minimum 19% tax on their foreign earnings, as well as charging a 14% tax on previously untaxed foreign income. Tax directors and their advisers say the proposals will harm economic growth and make US businesses less competitive in the global marketplace. They repeated that only comprehensive reform would fix the problems with the tax code.

Caroline Devlin, partner at Arthur Cox, explains the features of the Irish tax and legal system which make it an attractive investment location, and looks specifically at Chinese outbound investment in this regard.

Mexico has incorporated an independent public organisation – Procuraduría de la Defensa del Contribuyente (PRODECON) – which acts as a taxpayers’ ombudsman, with a mandate to guarantee and protect the constitutional and human rights of taxpayers. René Meza and César De la Parra of Chevez, Ruiz, Zamarripa y Cía outline the salient features of the dispute resolution mechanisms under PRODECON.

Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on the transfer pricing aspects of the OECD’s project to tackle base erosion and profit shifting.

Loreto Pelegrí