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  • Australia’s mining tax, the minerals resource rent tax (MRRT), continues to come under fire for the lack of revenue it is bringing in, leading to the possibility of the tax being redesigned.
  • Reduced compliance costs, improved service and how best to ensure that the UK tax system is implemented as parliament intended are some of the aims of a new academic organisation set up to look at how UK tax administration could operate better.
  • Germany is on the verge of enacting a company tax Bill which would impact multinationals with investments in German tax consolidated groups (organschaft).
  • Tax is not a struggle to the death, say Pascal Saint-Amans, director of the OECD’s Centre for Tax Policy and Administration and Will Morris, chair of the OECD’s business advisory branch (BIAC) tax committee and global tax policy director for GE.
  • On December 27 2012, the Spanish Government approved Law 16/2012, which provides for long-awaited reform of the legal and tax regime for Real Estate Investment Trusts (in Spain, Sociedades Cotizadas de Inversion en el Mercado Inmobiliario, or SOCIMIs).
  • The closure by Barclays of its structured capital markets (SCM) tax-related business unit is the second important announcement by a UK bank in less than a week concerning its tax reputation.
  • The OECD released its long-awaited report to the G20 on base erosion and profit shifting (BEPS) today. It has been welcomed by business and activists alike, hailing an era of greater dialogue and cooperation to address the weaknesses of the international tax system and tackle avoidance.
  • A challenge by the Portuguese tax authorities of a multinational’s cash pooling arrangement – because the authorities felt it inappropriately used the comparable uncontrolled price (CUP) – has been denied by an arbitration court. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
  • Tax experts from the Italian Revenues Agency (IRA) have given an important interpretative answer about transfer pricing transactions carried out by foreign commercial distributors held by resident groups, in a recent press conference.
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $24.4 billion Michael Dell / Silver Lake Dell Wachtell, Lipton, Rosen & Katz - Eiko Stange / Simpson Thacher & Bartlett - John Creed, Katharine Moir Debevoise & Plimpton / Hogan Lovells Acquisition $23.3 billion Liberty Global Virgin Media Shearman & Sterling / Ropes & Gray - John Baldry / Hogan Lovells Fried Frank Harris Shriver & Jacobson / Milbank Tweed Hadley & McCloy Acquisition $3.21 billion Total / SNAM / GIC / EDF / Singaporean Sovereign Fund Transport et Infrastructures Gaz France Sullivan & Cromwell Acquisition $2.1 billion Oracle Acme Packet Weil Gotshall and Manges / GTC Law Bingham McCutchen Acquisition $1.9 billion Silver Wheaton Vale (Salobo / Sudbury) Stikeman Elliott Acquisition $1.63 billion Charter Communications Cablevision Systems (Optimum West) Sullivan & Cromwell - Davis Wang Acquisition $1.2 billion Reliance Steel & Aluminum Metals USA Davis Polk & Wardwell - Rachel Kleinberg Wachtell, Lipton, Rosen & Katz - Deborah Paul Acquisition $1.1 billion Praxair NuCO2 Sullivan & Cromwell - Ronald Creamer Gibson Dunn & Crutcher Acquisition $267.5 million IKEA Pfleiderer (Russian business) Noerr - Elisey Balta Acquisition Undisclosed Guohua Energy Investment Hydro Tasmania (Musselroe) King & Wood Mallesons Herbert Smith Freehills TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Initial Public Offering $2.57 billion Zoetis J.P. Morgan / Merrill Lynch / Morgan Stanley Davis Polk & Wardwell - Michael Mollerus Secondary Offering $910 million NXP Semiconductors Barclays / Credit Suisse Simpson Thacher & Bartlett Davis Polk & Wardwell - John Paton Notes Offering $850 million Minerva Banco BTG Pactual / HSBC / Credit Suisse White & Case / Stoche, Forbes, Padis, Filizzola, Clapis Advogados / NautaDutilth Avocats Davis Polk & Wardwell - Kathleen Ferrell Convertible Senior Notes Offering $230 million KB Home Citigroup / Credit Suisse Munger, Tolles and Olson Davis Polk & Wardwell - Lucy Farr / Jones Day Registered Direct Offering $230 million Scorpio Tankers RS Platou Markets Seward & Kissel Davis Polk & Wardwell - Mary Conway Follow-On Offering $192.5 million Fleetmatics Barclays / Merrill Lynch Goodwin Procter / Maples and Calder Davis Polk & Wardwell - Rachel Kleinberg