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The Italian tax authorities are targeting multinationals with Italian subsidiaries through assessments focused on hidden permanent establishments (PE).

Joanne Hodge has rejoined New Zealand’s Bell Gully as a tax partner. She advises public and private companies and financial institutions on all aspects of corporate tax, including transactional work.

Striking a balance between bringing in revenue and attracting investment is a key concern for tax policymakers. But, as taxpayers at the Developing a Tax Environment for Growth and Competitiveness conference in Vienna last week pointed out, that balance is difficult to achieve because it is often based on undefined underlying assumptions.

Speaking at a conference in Austria last week, Jeffrey Owens, the former OECD tax chief, noted that income inequality has grown in the large majority of OECD countries in the last two to three decades, and that tax policy can have a profound impact on this trend, though he warned against a one-size-fits-all solution.

The UK Supreme Court is delivering its judgement in Prudential’s case against HM Revenue & Customs (HMRC) tomorrow. The court will decide whether legal professional privilege (LPP) should cover communications between taxpayers and accountants as well as lawyers.

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $8.2 billion Intercontinental Exchange NYSE Euronext Sullivan & Cromwell / Shearman & Sterling Bredin Prat / Wachtell Lipton Rosen & Katz / Slaughter & May / Stibbe Acquisition $3.46 billion Energetický a Prumyslový Holding Slovenský Plynárenský Priemysel (GDF SUEZ / E.ON) Baker & McKenzie Bredin Prat - Yves Rutschmann / De Brauw Blackstone Westbroek / Freshfields Brucjhaus Deringer Acquisition $2.82 billion JSC Atomredmetzoloto Uranium One Ashurst / Stikeman Elliott - John Lorito, Katy Pitch Goodmans / Cassels Brock & Blackwell Acquisition $1.7 billion Ardagh Group Compagnie de Saint-Gobain Freshfields Bruckhaus Deringer / Shearman & Sterling Cravath Swaine & Moore / Bredin Prat - Sébastien de Monès Acquisition $1.45 billion Saputo Morningstar Foods Stikeman Elliott / Jones Day Skadden, Arps, Slate, Meagher & Flom Acquisition $1.05 billion Denbury Resources ConocoPhillips (Montana and North Dakota properties) Vinson & Elkins - Todd Way In-House Counsel - Ronald Schultz Acquisition $764 million Stryker Corporation Trauson Holdings Company Sullivan & Cromwell Ashurst Acquisition $750 million The Swatch Group Harry Winston Diamond Stikeman Elliott Acquisition $467 million Ontario Teachers' Pension Plan SeaCube Container Leasing Sullivan & Cromwell - David Spitzer Acquisition $273.7 million NTUC Income Insurance Co-operative Savu Investments WongPartnership Lee & Lee Acquisition $150 million Comcast ARRIS Davis Polk & Wardwell - Avishai Shachar Troutman Sanders Acquisition Undisclosed Gamma-Dynacare Medical Laboratories MedAxio Insurance Medical Services Stikeman Elliott - Jean-Guillaume Shooner, Corine Di Maria Osler, Hoskin & Harcourt TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Equity and Convertible Notes Offerings $4 billion ArcelorMittal Goldman Sachs / Crédit Agricole / Deutsche Bank / Merrill Lynch Davis Polk & Wardwell - John Paton Notes Offering $3 billion Comcast Barclays / Goldman, Sachs / RBS / Deutsche Bank / UBS Davis Polk & Wardwell - Rachel Kleinberg Cahill Gordon & Reindel Notes Offering $1.25 billion Royal Bank of Canada RBC Capital Markets / J.P. Morgan Sullivan & Cromwell / Norton Rose Davis Polk & Wardwell - Harry Ballan Secondary Offering $1 billion Cobalt International Energy Davis Polk & Wardwell - Lucy Farr, Michael Mollerus Shearman & Sterling Exchange Traded Product Issuance Platform $1-2 billion (targeted) Boost Issuer Boost Management Maples & Calder Simmons & Simmons - Mark Sheiham Preferred Shares Offering $374 million KKR Financial Holdings Citigroup / Morgan Stanley / UBS / Wells Fargo Simpson Thacher & Bartlett Davis Polk & Wardwell - Po Sit High-Yield Senior Notes Offering $300 million Automotores Gildemeister J.P. Morgan Cleary Gottlieb Steen & Hamilton / Cariola Diez Pérez-Cotapos & Cia Davis Polk & Wardwell - Kathleen Ferrell

A new form of taxation of UK companies could be an alternative to interest deductibility, a parliamentary panel has been told.

Carlos Gabarró has rejoined Altalex Legal and Tax Consultants, a practice of about 20 professionals, in Barcelona as a tax partner. He was formerly with Ernst & Young.

BAE Systems; Ireland and US FATCA agreement; Shome Committee GAAR report; US tax reform; UK VAT; Vietnam VAT exemptions; Brazil sets new interest rates; DOTAS schemes.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement (Protocol) Spain US January 14 2013