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  • The Finnish Supreme Administrative Court has ruled against the Finnish Tax Administration on the grounds that tax law reclassification can only be made under general anti-avoidance provisions and not transfer pricing adjustment provisions.
  • China’s State Administration of Taxation (SAT) published its discussion draft on ‘Administrative Measures on the General Anti-Avoidance Rule (GAAR)’ this month, which outlines key principles and procedural guidelines for its implementation, but there is still more work to be done.
  • The European Court of Justice (ECJ) has ruled in favour of the admissibility of requests for preliminary rulings submitted by the Portuguese Tax Arbitral Court.
  • The European Commission’s pilot scheme looks to improve the framework for resolving cross-border VAT disputes, and while the project is making some positive strides in harmonising EU VAT, it requires better communication if it is to succeed.
  • HM Revenue & Customs (HMRC) will be granted the authority to issue ‘follower’ and ‘accelerated payment’ notices when the Finance Bill comes into effect later this month, forcing users of disclosed tax avoidance schemes to concede on tax disputes and make payments upfront to the revenue pending appeal.
  • Once again, the German Federal Fiscal Court has confirmed that the German provision regarding the tour operator margin scheme contradicts the provisions of the EU VAT Directive.
  • Three taxpayers, from Aricent Group, Cairn and GE, discuss the transfer pricing aspects of India’s new budget and how they expect them to impact businesses.
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  • Sheikh Salman Bin Hassan Al-Thani has become chief financial and tax officer of the Qatar Financial Centre Authority (QFC Authority), the commercial and strategic arm of the Qatar Financial Centre (QFC) and responsible for developing and ensuring compliance with the QFC regulations and rules comprising the QFC’s legal and tax environments.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.68 billion BTG Pactual Banca della Svizzera Italiana (BSI) Skadden - James Anderson, Alex Jupp, Melanie Shaw, Thomas Kim Acquisition $170 million Aalberts Industries Impreglon SE Hengeler Mueller Acquisition $100 million ServiceNow Inc. Neebula Systems Ltd. Fenwick & West - Adam Halpern, Will Skinner, Gilad Yacubovich Acquisition Undisclosed Autodesk, Inc. Shotgun Software Inc. WSGR Fenwick & West - Adam Halpern, Idan Netser, Zach Jones, Arnold Keizer Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $1.77 billion NN Group N.V. Deutsche Bank AG, London Branch, ING Bank N.V., J.P. Morgan Securities plc, Morgan Stanley & Co. International plc Allen & Overy Davis Polk & Wardwell - John Paton, Alon Gurfinkel, Rhiannon Nakano Bonds Offering $1 billion Greenland Global Investment Ltd BOCI Asia Limited, The Hongkong and Shanghai Banking Corporation Limited, J.P. Morgan Securities plc and Deutsche Bank AG Davis Polk & Wardwell - Alon Gurfinkel, Maer Harel, Lena Qiu Linklaters Senior Secured Credit Facilities $1 billion Rovi Corporation Morgan Stanley Senior Funding, Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated, Fifth Third Bank and SunTrust Robinson Humphrey, Inc. Cooley Davis Polk & Wardwell - Craig Phillips, Neetin Gulati Credit Enhanced Convertible Bonds Offering $161 million China Yongda DBS Bank Ltd., UBS AG Linklaters Davis Polk & Wardwell - Alon Gurfinkel, Sarah Joy