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  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.1 billion Permira Funds Atrium Innovations Skadden, Arps, Slate, Meagher & Flom - Katherine Bristor, Brian Krause Acquisition Undisclosed Yucaipa Fresh & Easy (Tesco) Davis Polk & Wardwell - Kathleen Ferrell Acquisition Undisclosed KKR Gland Pharma Limited Amarchand & Mangaldas; Simpson Thacher & Bartlett, EY EY; KPMG Acquisition/stake sale Undisclosed Religare Religare Macquarie Wealth Management (Macquarie Group) Vaish Associates Amarchand & Mangaldas Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Convertible notes offering $1.25 billion Yahoo! JP Morgan Securities; Goldman, Sachs Davis Polk & Wardwell - Rachel Kleinberg, Catherine Paskoff Chang, Vinay Prabhakar SEC-registered notes offering $350 million Aon Morgan Stanley; Merrill Lynch, Pierce, Fenner & Smith; Deutsche Bank; JP Morgan Davis Polk & Wardwell - Samuel Dimon, Jonathan Cooklin Common stock offering $90 million Cardiovascular Systems Merrill Lynch, Pierce, Fenner & Smith Fredrikson & Byron Davis Polk & Wardwell - Rachel Kleinberg, Catherine Paskoff Chang
  • The Green Budget Europe Annual Conference discussed new approaches for environmental fiscal reform and emissions trading at the Swiss, EU and international level and honoured Professor Frank Convery as 2013 Environmental Fiscal Reformer of the Year, reports Constanze Adolf, director of Green Budget Europe’s Brussels office.
  • Tom Seymour The recently elected Australian government has made the first move towards repealing the Minerals Resource Rent Tax (MRRT) and the carbon pricing mechanism, with effect from July 1 2014, with the release of legislation to give effect to the repeal. As the introduction of the MRRT, which applies to Australian iron ore and coal miners, was linked to a number of tax concessions, the government's position is that some, but not all, of these tax concessions are to also now be repealed or amended. These include:
  • Nina Sava This month the Romanian Government has approved an Emergency Government Ordinance for the introduction of a new tax as of January 1 2014. The so-called construction tax payable to the state budget (distinct from the existing building tax which is income for the local budgets) stems from the commitment the government has made towards the IMF to increase the efficiency of the Romanian fiscal system and to ensure financial stability of the national economy, in other words to increase tax revenue. Moreover, in line with the objectives of the governing programme to extend the "taxable base", the Romanian government is now committed to tax what has not been taxed before. Romania traditionally subjects buildings to tax (the level of building tax for legal persons is maximum 1.5% of the gross accounting value of the asset, or in the range of 10-40% in case of buildings which have not been revalued). Construction tax, however, is targeted at constructions other than buildings and which consequently are not subject to building tax. Constructions subject to the new tax include inter alia power plants, oil & gas wells, drilling and production platforms, mine shafts, railway/road/telecommunications infrastructure, constructions for transport of electricity and many more. In practice, the list may be virtually open, as in principle any construction not subject to building tax should be subject to construction tax.
  • Gabriel Bernal Over the last couple of years, Chile has been experiencing significant changes with regards to transfer pricing, which have been changing the way local taxpayers view their inter-company transactions. Even though Chilean transfer pricing legislation was introduced in 1997, being amongst the first in the region, Article 38 of the Chilean Income Tax Law (ITL) seemed to be insufficient, since it did not include relevant technical matters such as a detailed description of the TP methods, nor did it incorporate internationally accepted practices on this matter.
  • Over the past four years, the Indonesian Directorate General of Tax (DGT) has been placing great focus on the tax potential from related-party transactions within multinational groups of companies. The DGT has issued regulations on transfer pricing guidelines, developed its human resources, equipped itself with commercial database, and undertaken audits particularly when there are intercompany transactions. Sri Wahyuni of SF Consulting provides an overview of the changes and explains what taxpayers need to do to guard against audit.
  • Thuan Pham Over the last three decades, Vietnam has received a large amount of official development assistance (ODA) from other countries. As part of this, it has established preferential policies for foreign contractors (individuals) who carry out projects/programmes funded by ODA with regard to visas, foreign exchange, residential registration, work permits, customs duty and, most importantly, exemption from personal income tax on the salary/wages they receive during the time they work in Vietnam on ODA projects. There are some limitations, however, to who can enjoy such privileges, as not all those working on ODA projects/programmes are entitled to such benefits. Certain criteria must be satisfied and exemption is not conferred automatically. Individuals that meet the criteria must then obtain certification of such from the relevant ODA management agency, after which they must apply to the local tax authorities for a tax exemption certificate.