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With the backdrop of an increasing budget deficit in an election year, Julia Gillard’s Labor Government has targeted large corporates, multinationals and the mining industry in an attempt to raise additional revenue. Leon Mok, executive director at Baker Tilly Pitcher Partners, outlines the key measures proposed in the Australian federal budget affecting the corporate and international space.

Cristiane Magalhães and Fernanda Fiasco Ribeiro, of Machado Associados, explore a recent opinion (Opinion 202/2013) issued by the Office of the Attorney General of the National Treasury (PGFN) about the tax exemption applicable to the distribution of profits and dividends established by Article 10 of Law 9249/95.

Norway is to implement changes to the corporate tax regime in a bid to stimulate investment and maintain competitiveness with other European countries, with a company tax cut and an increased depreciation allowance on the horizon.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Malta Russia April 24 2013 Tax Information Exchange Agreement Netherlands UK May 1 2013 (entered into force) Double Taxation Avoidance Agreement Japan UAE May 2 2013 Tax Information Exchange Agreement Argentina Isle of Man May 4 2013 (entered into force) Double Taxation Avoidance Agreement Bahrain Barbados May 6 2013 (ratified)

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $1.5 billion Sumitomo Mitsui Financial Group PT Bank Tabungan Pensiunan Nasional Linklaters Cleary Gottlieb Steen & Hamilton Acquisition $600 million OMERS Private Equity Civica Weil, Gotshal & Manges - Joanne Etherton Acquisition $370 million Baidu PPS Davis Polk & Wardwell - Kathleen Ferrell Cadwalader, Wickersham & Taft Acquisition $240.1 million Sprott Inc. Sprott Resource Lending Corp. Heenan Blaikie Stikeman Elliott - Dean Kraus, Jill Winton Acquisition $214 million Perpetual The Trust Company Herbert Smith Freehills King & Wood Mallesons - Darren McClafferty Acquisition Undisclosed Charter Hall / PSP Investments FKP Property Group (Gasometer 2 Brisbane) King & Wood Mallesons Thomson Lawyers Acquisition Undisclosed Hain Celestial Ella's Kitchen Group DLA Piper Davenport Lyons - Gerald Montagu Acquisition Undisclosed Sana Kliniken Klinikum Offenbach Luther Rechtsanwaltsgesellschaft - Jens Röhrbein TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS SEC Registered Guaranteed Notes Offering $4 billion CNOOC Bank of China (Hong Kong) / Bank of China / BOCI Asia / China International Capital Corporation / Citigroup / Credit Suisse / Goldman Sachs / J.P. Morgan / Merrill Lynch / CCB / ICBC / Scotia Capital / Société Générale Davis Polk & Wardwell - Lucy Farr / Walkers Linklaters / Commerce & Finance Law Offices Secondary Public Offering $1.82 billion RTL Group Hengeler Mueller / Davis Polk & Wardwell Secondary Offering $1.3 billion Cobalt International Energy Citigroup Davis Polk & Wardwell - Michael Mollerus Shearman & Sterling Initial Public Offering $1.27 billion ING Morgan Stanley / Goldman Sachs / Citigroup Sullivan & Cromwell Davis Polk & Wardwell - Rachel Kleinberg Notes Offering $1 billion Texas Instruments J.P. Morgan / Morgan Stanley Davis Polk & Wardwell - Rachel Kleinberg Notes Offering $650 million Praxair Citigroup / Credit Suisse / RBS Cahill Gordon & Reindell Davis Polk & Wardwell - Samuel Dimon

In the second of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, examines the use of expert witnesses in transfer pricing cases and in giving valuation opinions.

Australian industry group wants tax cuts; CBI proposes tax principles; Finnish MAP; expert evidence in Canadian tax cases; indirect tax hikes in Japan; US Marketplace Fairness Act; Rand Paul on FATCA

In a ruling handed down May 6, 2013, Canada's Federal Court of Appeal ordered that portions of a Crown pleading be struck out on Monday for suggesting that a tax deduction may be disallowed on the basis that the conduct of the taxpayer in incurring the expense was egregious or repulsive.

Joseph Nega, senior legislation counsel to the US Congress Joint Committee on Taxation, will become a new Tax Court judge if his nomination, which President Obama sent to the Senate on Wednesday, is approved.

Greg Elliott has succeeded Michael Velten as head of tax for CLSA, the Asian banking group,. He was formerly managing director – group tax for Deutsche Bank in Hong Kong. Velten became a partner of Deloitte South East Asia in May, with the task of building up the firm’s financial services tax practice.