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Deals of the week - April 28 2014

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Joint Acquisition $35.5 billion Yamana Gold and Agnico Eagle Mines Osisko Mining Corp. Paul, Weiss, Rifkind, Wharton & Garrison; Davies Ward Phillips & Vineberg Stikeman Elliott Interconditional Transaction $5.25 billion GlaxoSmithKline Novartis Slaughter and May - Dominic Robertson, James Hume, Emma Game, Alexander Berend

April 28 2014

UK continues to push transparency agenda with beneficial ownership registry

David Cameron, UK Prime Minister, wants all British overseas territories to follow the UK in publishing a central registry of beneficial ownership information. Tax transparency is undoubtedly increasing, but this latest move has raised concerns that, if implemented, foreign investment into the UK would suffer.

Matthew Gilleard, April 27 2014

New Greek transfer pricing guidance provides clarity

Greece’s Finance Minister has issued a ministerial decision that provides guidance on the contents of the transfer pricing documentation file, the parties subject to the transfer pricing rules and exemptions , language requirements, transfer pricing documentation methods, and the content of the summary information table.

April 27 2014

European Commission tells Dutch authorities to stop unequal taxation of foreign insurance companies

The European Commission has told the Netherlands to end the biased taxation of Dutch-sourced dividends paid to EU/EEA insurance companies.

Aaran Fronda, April 24 2014

Wednesday is decision day for European Court on UK financial transaction tax challenge

In a move that could bring the political discussion to a head much sooner than expected, The European Court of Justice has brought forward its ruling on the UK’s challenge to the proposed EU financial transaction tax (FTT). The decision is now expected next Wednesday, April 30.

Aaran Fronda, April 24 2014

France latest to move ahead of OECD on BEPS with hybrid mismatch guidelines

French authorities have released draft guidelines for legislation enacted at the end of December targeting hybrid mismatch arrangements, an aspect of international tax practice the OECD is also seeking to tackle as part of its BEPS Action Plan.

Matthew Gilleard, April 24 2014

Caterpillar: A BEPS case study

At the end of March, multinational manufacturer of construction and mining equipment, Caterpillar, was brought before the US Senate to explain its tax affairs, accused of profit shifting and aggressive tax planning. Mirna Screpante, tax researcher, describes the tax effects caused by the model currently accused of avoiding taxes.

April 23 2014

CEOs acknowledge tax as a factor in business location decisions

Corporate taxpayers say tax is an influential factor when an international business is deciding where to locate itself.

Matthew Gilleard, April 23 2014

Survey of company bosses shows appetite for more tax transparency

A survey of chief executive officers about the global economy has produced a number of headline-grabbing figures about their attitudes to tax, such as a surprising high level of support for country-by-country reporting, which would require them to disclose their companies’ income, profit and tax in each country in which they operate.

Ralph Cunningham, April 23 2014

Tax lawyer to chair Loyens' executive board

Christian Chéruy has been appointed chairman of Loyens & Loeff’s executive board. He advises clients on corporation tax and international tax and was previously head of the firm’s tax practice in Brussels and was also country managing partner of the Brussels office.

April 23 2014

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