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Peru’s controlled foreign corporation (CFC) rules have been in place from the start of the year. Eduardo Joo Garfias, associate at Amprimo & Flury Abogados in Lima, Peru, analyses their impact to date, and identifies where there is room for improvement.

Portugal is on the verge of revealing a comprehensive tax reform plan which could see the corporate tax rate reduced to 18%.

Australia is gearing up to try and achieve meaningful outcomes on action to tackle base erosion and profit shifting (BEPS) during its chairmanship of the G20 next year.

BEPS reaction; BEPS report; French green tax policy; EU VAT place of supply change; PPG Holdings case; ECJ’s impact on tax policy; Australia on profit shifting

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Merger $27.9 billion Bpifrance French State / Caisse des Dépôts Jones Day BDGS / Bredin Prat - Yves Rutschmann Acquisition $10.7 billion Telefonica E-Plus McDermott Will & Emery Allen & Overy Acquisition $5.83 billion Activision Blizzard Vivendi Wachtell, Lipton, Rosen & Katz - Jodi Schwartz / Skadden, Arps, Slate, Meagher & Flom Acquisition $3.75 billion Fieldwood Energy Apache Corporation Simpson, Thacher & Bartlett / Vinson & Elkins Bracewell & Giuliani - Elizabeth McGinley Acquisition $2.7 billion Cisco Systems Sourcefire Fenwick & West - Ron Schrotenboer Morrison & Foerster Acquisition $2.34 billion ASAC II Vivendi Sullivan & Cromwell - Diana Wollman, David Passey Acquisition $2.3 billion PacWest Bancorp CapitalSource Sullivan & Cromwell - Ronald Creamer Wachtell Lipton Rosen & Katz Merger $1.85 billion Ambuja Cements Holcim India Amarchand & Mangaldas Homburger Acquisition $1.3 billion Spartan Stores Nash Finch Skadden, Arps, Slate, Meagher and Flom Morgan, Lewis & Bockius Acquisition $1.22 billion Funke Mediengruppe Axel Springer Linklaters Hengeler Mueller Acquisition $1.2 billion Davis + Henderson Corporation Harland Financial Solutions Stikeman Elliott Paul, Weiss, Rifkind, Wharton & Garrison Acquisition $575 million Hanesbrands Maidenform Brands Davis Polk & Wardwell - Neil Barr Acquisition $345 million FMC Corporation Epax BA-HR / Weil, Gotshal & Manges - Jared Rusman Acquisition Undisclosed AVIC Thielert Noerr - Michaela Engel Acquisition Undisclosed Dropbox Endorse Corporation Fenwick & West - Adam Halpern, Larissa Neumann Merger Undisclosed Omnicom Group Publicis Groupe Latham & Watkins Wachtell, Lipton, Rosen & Katz - Deborah Paul Acquisition Undisclosed TowerBrook Capital Partners Metallum Holding Kirkland & Ellis - Ian Taplin / Bredin Prat Allen & Overy TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Private Placement $877.1 million Zodiac Aerospace Bredin Prat / Hengeler Mueller Herbert Smith Acquisition Financing $735 million Crestview Partners Credit Suisse / BMO Capital Markets Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Kathleen Ferrell Notes Reopening $225 million Harbinger Group Credit Suisse / Deutsche Bank / Jefferies Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Samuel Dimon, Michael Farber Acquisition Financing $195 million XPO Logistics Credit Suisse Ackerman Senterfitt / Wachtell Lipton Rosen & Katz Davis Polk & Wardwell

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Japan Portugal Entered into force July 28 2013

The American Bar Association (ABA) has named Dechert partner Michael Hirschfeld chair of its Section of Taxation.

The Ghana Revenue Authority (GRA) is planning to launch a transfer pricing unit within its large taxpayers office. The launch had been scheduled for the end of June but no new configuration date has yet been issued.

Ireland has long been one of the most attractive locations for the establishment of holding companies of both listed and private multinational companies seeking to optimise their operational and fiscal performance, argue Peter Vale and Sarah Meredith of Grant Thornton.

Taxpayers, advisers and academics have expressed concern over the impact of European Court of Justice (ECJ) rulings on member states’ tax policy in a UK government report about EU membership.