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Rajendra Nayak

Clint O’Connell When it comes to offices, retail and factories in Cambodia, most often the lease agreement is concluded between two Cambodian corporate entities. The landlord could be a property development/investment company and the tenant is usually a corporate entity as well. In Cambodia, a unique set of tax obligations, in terms of VAT and withholding taxes, applies to the rental payments. In some extreme cases, unforeseen tax implications can render the project uneconomical.

Bob van der Made After the European Commission presented its draft Directive for the financial transaction tax (FTT) to the European Council on February 14 2013 under the EU's enhanced cooperation procedure, the national fiscal attachés of the 27 EU member states started a series of technical discussions in the Council Working Party on Tax Questions – Indirect Taxation under the Irish EU Presidency on February 21 2013. This process is referred to as article-by-article reading or first reading whereby the fiscal attachés go through the Directive chronologically and can propose amendments. They can also ask the Commission, which is present throughout, as the proposer of the EU legal act, to clarify the articles and their impact further.

Gonzalo Schmidt

John Leopardi

Paul Stepak

Donka Pechilkova New rules for administrative cooperation between EU member states have been required to respond to the challenges of globalisation. This type of assistance in the field of direct taxation has been established since 1977. At that time the cooperation was regulated by Council Directive 77/799/EC. That initial directive was replaced with Council Directive 2011/16/EU.

The political momentum for changing the international tax system has never been greater. The OECD’s work on issues concerning base erosion and profit shifting (BEPS) has been thrust firmly into the spotlight. As we await the organisation’s roadmap on addressing BEPS in July, Joe Dalton asks stakeholders on all sides of the debate: how should the international tax system be fixed, and what are the consequences for the multinationals operating within it?

Transfer pricing regimes in Asia are developing quickly. With India’s advance pricing agreement programme, a growing culture for dispute in China and changes to Indonesia’s legislation, to name but a few recent developments, it is important taxpayers keep themselves up to date with best practice.

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $5.8 billion Sobeys / Empire Company Canada Safeway McCarthy Tétrault / Stikeman Elliott / Sullivan & Cromwell Latham & Watkins / Blake, Cassels & Graydon Acquisition $5.4 billion Unilever Plc / Unilever NV Hindustan Unilever Davis Polk & Wardwell Acquisition $4.3 billion Tenet Healthcare Vanguard Health Systems Gibson Dunn & Crutcher Skadden, Arps, Slate, Meagher & Flom Acquisition $600 million Adobe Systems Neolane Weil, Gotshal & Manges - Helyn Goldstein Orrick Acquisition $469.5 million Ontario Teachers' Pension Plan SeaCube Container Leasing Stikeman Elliott / Sullivan & Cromwell Conyers Dill & Pearman / Skadden, Arps, Slate and Meagher & Flom Acquisition $395 million Thoma Bravo Keynote Systems Kirkland & Ellis Fenwick & West - David Forst, Jay Cosel Acquisition $129 million York Capital Management Primus Telecommunications Group Stikeman Elliott - John Lorito / Akin Gump Strauss Hauer & Feld Joint Venture $104.2 million Tognum JSC Transmashholding Noerr Merger Undisclosed Mitsubishi Heavy Industries Hitachi Noerr / Herbert Smith Freehills / Nishimura & Asahi / Werksmans Attorneys / WKB Wiercinski, Kwiecinski, Baehr / Zepos & Yannopoulos Acquisition Undisclosed Olympus Partners Par-Pak Kirkland & Ellis / Stikeman Elliott Torys / Blake, Cassels & Graydon / Weil, Gotshal & Manges Acquisition Undisclosed Rockwater Poseidon Stikeman Elliott - Douglas Richardson TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Senior Notes Offering $325 million Quicksilver Resources Davis Polk & Wardwell - Michael Mollerus Cravath, Swaine & Moore Initial Public Offering $144.4 million PTC Therapeutics J.P. Morgan / Credit Suisse Wilmer Cutler Pickering Hale and Dorr Davis Polk & Wardwell - Michael Mollerus American Depositary Shares Offering $133.3 million Himax Technologies Citigroup / Merrill Lynch / Chardan Capital / Credit Suisse Conyers Dill & Pearman / Baker & McKenzie / Davis Polk & Wardwell Shearman & Sterling / Lee and Li Secondary Offering $119.6 million Rexnord Deutsche Bank / Goldman Sachs Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Samuel Dimon