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Mark Whitehouse and Simon Wilks PwC Legal and PwC There have been a number of features of the UK tax dispute landscape over the course of the past year which are worthy of note. In the first instance, the UK's Public Accounts Committee (PAC) has taken a keen interest in tax compliance and tax avoidance. The enquiries of the PAC have included within their remit a number of important issues for large corporate groups. The PAC has summoned large corporate entities to discuss their tax affairs, including corporate groups such as Starbucks, Google and Amazon. The result of this is that this has created an environment in which many large corporate groups find their tax affairs under unusually high scrutiny.

House of Lords on UK tax code; tax breaks for shale gas; IRS wins LILO case; Italian domestic transfer pricing rules; Australia GST compliance; Commissionaire to LRD; Extra funding for ATO.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.1 billion Brookfield Property Partners Industrial Developments International Weil, Gotshal & Manges - Scott Sontag Alston & Bird - Jennifer Weiss Acquisition $405 million AOL Adap.tv Fenwick & West - Ronald Schrotenboer, Zach Jones Acquisition $347 million Samsung Group Novaled Skadden Arps Slate Meagher & Flom Sullivan & Cromwell Acquisition $181.5 million TreeHouse Foods Associated Brands Winston & Strawn / Stikeman Elliott - Luc Bernier, Éric Lévesque Torys Acquisition $126 million York Capital Management Primus Telecommunications Group (North American retail telecom operations) Stikeman Elliott - John Lorito Acquisition $122.5 million Estrella International Energy Services San Antonio Internacional Colombia Aird and Berlis / Estudio Garrido Davis Polk & Wardwell / Davies Ward Phillips & Vineberg / Cárdenas & Cárdenas Acquisition Undisclosed Crossroads C&I GlassCell Isofab Stikeman Elliot / Kirkland & Ellis Merger Undisclosed Theraclone Sciences PharmAthene Fenwick & West - Michael Solomon, Amanda Athanasiou Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Loan Facility Refinancing $1.49 billion Hologic Goldman Sachs Brown Rudnick Davis Polk & Wardwell Block Trade $1.1 billion LyondellBasell Industries Barclays Capital Baker Botts Davis Polk & Wardwell - Michael Farber Notes Offering $1 billion Baidu JP Morgan / Goldman Sachs Skadden, Arps, Slate, Meagher & Flom / Han Kun Law Offices / Maples and Calder / Li & Partners Davis Polk & Wardwell - Alon Gurfinkel Initial Public Offering $383 million Sprouts Farmers Market Goldman Sachs /Credit Suisse Morgan, Lewis & Bockius Davis Polk & Wardwell - Samuel Dimon Notes Offering $300 million Bankrate Wachtell, Lipton, Rosen & Katz - Joshua Holmes Initial Public Offering $140 million Ardmore Shipping Morgan Stanley Seward & Kissel Davis Polk & Wardwell - Michael Mollerus

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement New Zealand Vietnam August 5 2013 Double Taxation Avoidance Agreement (Protocol) India Morocco August 8 2013

On August 2 2013, the Brazilian Ministry of Finance issued ordinance 427/2013, which finally provides the interest rate spread that was mentioned, but not specified, in Law 12.766/2012.

Keith Reams and Robin Hart, of Deloitte, explain how knowing the venue, and if possible being able to determine the venue, provides taxpayers with the ability to better manage the negotiation of transfer pricing controversies.

Taxpayers must be more aware of the impact transfer pricing adjustments are having on their indirect tax liabilities, advisers have said. Taking an internal approach can help taxpayers reduce the number of transfer pricing adjustments by ensuring prices are gathered from consistent sources.

Iron ore company Fortescue Metals has lost its attempt to throw out the minerals resource rent tax (MRRT) in Australia’s High Court meaning the tax is here to stay, for now.

Keith Reams and Robin Hart, of Deloitte, detail the finer points of managing transfer pricing controversy negotiations.

US life insurance company John Hancock has lost its Tax Court case concerning lease-in-lease-out (LILO) and sale-in-lease-out (SILO) transactions, meaning the Internal Revenue Service (IRS) continues its record of having won all cases on this issue. However, the IRS may have caused itself future difficulties by making an economic substance argument.