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Canada has followed suit with the US and has omitted references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation.

In Michael O’ Sullivan v Canada Life Insurance [Ireland] Limited, the Irish High Court ruled on two aspects relating to the transfer of Personal Retirement Savings Account (PRSA) abroad pursuant to the Occupational Pension Schemes and Personal Retirement Savings Accounts (Overseas Transfer Payments) Regulations 2003 (the Regulations).

The limitation-of-benefit clause in the India-Singapore treaty, offers greater clarity and comfort for investors residing in the country, helping to make Singapore India's top source of foreign direct investment.

Revenue recently published their annual report for 2013. The report sets out some of the major trends in terms of Revenue’s audit and enforcement activity in Ireland, during 2013. Outlined below is a summary of some of the key points raised in the report.

Ricardo Rendon and Eduardo Valenzuela, of Chevez, Ruiz, Zamarripa y Cía, assess the new tax provisions applicable to taxpayers in Mexico following energy reforms of the oil and gas sector.

The growing complexity of worldwide transfer pricing rules continues to expand documentation requirements, transparency initiatives and audits, all of which create challenges for multinational companies, believe Nancy Manzano and Bernadette Pinamont of Vertex.

A spate of recent examples indicates that inversion transactions are as popular as they have ever been, with Pfizer’s attempted deal with AstraZeneca highlighting that companies in the pharmaceuticals industry are increasingly using the inversion option. William Fry Tax Advisors, the Irish member firm of Taxand, look at why this is, and analyse why Ireland is proving to be the location of choice for newly-formed companies post-inversion.

More and more employees are being sent on temporary foreign assignments by their companies, but fail to think of the tax implications. There are, however, many risks inherent in foreign assignments, explains Ulrike Hasbargen of EY.

Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the factors influencing taxpayer decisions to locate in Ireland, debunking the idea that such decisions are solely tax-driven.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Proposal To Acquire $6.8 billion Tyson Foods Inc. The Hillshire Brands Company Davis Polk & Wardell LLP - Neil Barr Acquisition $370 million Mitsubishi UFJ Lease & Finance Company Engine Lease Finance and Beacon Intermodal Leasing Davis Polk & Wardell LLP - Kathleen Ferrell Mori Hamada & Matsumoto and Milbank, Tweed Hadley & McCloy LLP Acquisition $260 million Shire plc Lumena Pharmaceuticals Inc. Davis Polk & Wardell LLP Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $2.5 billion Celgene Corporation Merrill Lynch, Pierce, Fenner & Smith Inc., Credit Suisse Securities LLC, Goldman Sachs & Co., Morgan Stanley & Co. LLC Poskauer Rose LLP Davis Polk & Wardell LLP - Neil Barr Public Offering $2 billion JD.com Merrill Lynch, Pierce, Fenner & Smith Inc., UBS Securities LLC Skadden, Arps, Slate, Meagher & FlomLLP, Zhong Lun Law Firm, Maples and Calder Davis Polk &Wardell LLP - John Paton, Rhiannon Nakano Notes Offering $2 billion Caterpiller Barclays Capital Inc., J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Inc. Sidley Austin LLP Davis Polk & Wardell LLP - Michael Mollerus, Ameya Lae Convertible Notes Offering $1.3 billion Cobalt International Energy Inc. Goldman Sachs & Co., RBC Capital Markets LLC Shearman & Sterling LLP Davis Polk & Wardell LLP - Lucy Farr, Michael Mollerus, Vinay Prabhakar Senior Notes Offering $500 million Mead Johnson Nutrition Company Citigroup Global Markets Inc., Goldman Sachs & Co., J.P. Morgan Securities LLC, Morgan Stanley & Co. LLC Mayer Brown LLP Davis Polk & Wardell LLP - Harry Ballan, Gregory Hannibal Notes Offering $500 million Eastman Chemical Company J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Inc., Wells Fargo Securities LLC Jones Day Davis Polk & Wardell LLP - Kathleen Ferrell, Sam Van Peperstraete Acquisition Financing $485 million Shearer's Foods Credit Suisse Securities LLC, Deutsche Bank Securities Kirkland & Ellis LLP Davis Polk & Wardell LLP Credit Enhanced Bonds Offering $136 million Rizhao Port (Hong Kong) Company Ltd. ABCI Capital Ltd., Barclays Bank PLC DLA Piper, DHH Law Firm Davis Polk & Wardell LLP - Alon Gurfinkel, Dominic Foulkes Senior Notes Offering $50 million Scorpio Tankers Inc. Stifel, Nicolaus & Company, Incorporated, Deutsche Bank Securities Inc., Jerfferies LLC Seward & Kissel LLP Davis Polk & Wardell LLP - Harry Ballan, William Curran