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The Finnish Supreme Administrative Court (SCA) rendered a landmark decision on March 4 2013, explains Kennet Pettersson of Ernst & Young. The main dispute concerned location savings and whether such benefits could be allocated to a foreign low cost subsidiary. Though the SCA’s decision rejected the locations savings which were sought to be applied in the case at hand, the decision clearly recognises location savings and the allocation of these benefits to a low cost subsidiary provided similar functions were conducted in Finland before the reorganisation and benefits availed can be clearly crystallised.

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $3.9 billion KKR Gardner Denver Simpson Thacher & Bartlett Skadden, Arps, Slate, Meagher & Flom Acquisition $783.2 million Eurazeo (Edenred) Bredin Prat (Yves Rutschmann, Sébastien de Monès) Acquisition $689.7 million London Stock Exchange LCH.Clearnet Freshfields Bruckhaus Deringer / Herbert Smith Freehills Clifford Chance Acquisition $171 million La Mancha Alacer Gold (Frog's Leg Mine / Lake Greta / Avoca) Stikeman Elliott - Dean Kraus Merger Undisclosed Cole Credit Property Trust III Cole Holdings Wachtell, Lipton, Rosen & Katz / Venable / Morris, Manning & Martin Sullivan & Cromwell TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Temporary Guarantee $23.4 billion Crédit Immobilier de France French State Bredin Prat Clifford Chance Notes Offering $6.5 billion Freeport-McMoRan Copper & Gold Merrill Lynch / J.P. Morgan / BNP Paribas / Citigroup Davis Polk & Wardwell - Kathleen Ferrell Cravath, Swaine & Moore High-Yield Notes Offering $1.5 billion Equinix J.P. Morgan / Barclays / Citigroup / Merrill Lynch / Deutsche Bank Davis Polk & Wardwell - Rachel Kleinberg Cahill Gordon & Reindel Notes Offering $500 million Praxair Citigroup Cahill Gordon & Reindell Davis Polk & Wardwell - Samuel Dimon Senior Notes Offering $400 million Lexmark International J.P. Morgan / Citigroup Thompson Hine Davis Polk & Wardwell - Michael Farber Multi-Option Facility Agreement $174 million Independence Group National Australia Bank King & Wood Mallesons

Ireland's Court of Criminal Appeal has set aside the six-year sentence imposed on a Dublin businessman for failing to pay €1.6m ($2.08 million) in import duty. The court ruled that the sentence should be reduced to two years.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Bhutan India March 4 2013

The Irish Revenue Commissioners have very broad and far reaching powers under Section 908 of the Taxes Consolidation Act, 1997 (TCA) to investigate tax evasion.

Australian corporate tax deadline; Vietnamese tax compliance; Danish corporate tax cut; EU ECON; Indian customs; Swiss VAT deduction; Japanese tax disputes; Portuguese CUP

Michael Faber has joined Cooley in New York as a partner in its tax practice.

It is fair to say the Indian budget this month left corporate investors disappointed. Expectation was high for business-friendly tax measures but few appeared, save for an announcement that safe harbour rules and guidance are imminent.

The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybrid instruments.

A former Chinese State Administration for Taxes official has taken a position with Baker & McKenzie’s tax and transfer pricing practice in New York.