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  • Law No. 9430 (in force since 2007) subjects import transactions related to products, services and rights performed by Brazilian legal entities with related parties abroad to transfer pricing control in Brazil.
  • The UK Parliament’s Public Accounts Committee (PAC) has called for government action to clamp down on seemingly successful multinational companies that pay little tax in the country, as well as criticising HM Revenue & Customs (HMRC).
  • The European Commission has another busy year ahead as the financial transaction tax (FTT) and VAT reform go full speed ahead, while it looks at ways to crack down on tax avoidance and it looks to press on with the common consolidated corporate tax base (CCCTB). Salman Shaheen speaks to Algirdas Šemeta, Commissioner for Taxation and Customs Union, Audit and Anti-Fraud about what he has planned for 2013.
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $6.8 billion ConAgra Foods Ralcorp Holdings Davis Polk & Wardwell - Neil Barr Wachtell, Lipton, Rosen & Katz - Eiko Stange Acquisition $2.5 billion Apollo Global Management McGraw-Hill Education Paul, Weiss, Rifkind, Wharton & Garrison / Morgan Lewis and Bockius Wachtell, Lipton, Rosen & Katz / Clifford Chance Acquisition $2.4 billion Dell Quest Software Stikeman Elliott Latham & Watkins Portfolio Investment $1.8 billion Andra AP-fonden (AP2) South Korean National Pension Fund / Tishman Speyer Davis Polk & Wardwell - Po Sit Shin & Kim / Gibson, Dunn & Crutcher Acquisition $1.6 billion Grupo Financiero Banorte Afore Bancomer Covington & Burling - Robert Heller / Jones Day / Haynes & Boone Sullivan & Cromwell Asset disposals $1.02 billion Foncière des Murs / Grosvenor ANF Immobilier Bredin Prat - Sébastien de Monès, Edouard Sicot Acquisition $613.6 million TAG Immobilien TLG Wohnen Noerr - Carsten Heinz Acquisition $425.2 million Gemshine Investments Sengkang Mall Herbert Smith Freehills / WongPartnership Shook Lin & Bok Acquisition $250 million Stella-Jones McFarland Cascade Holdings Stikeman Elliott Acquisition $141 million Cisco Systems Cariden Technologies Fenwick & West - Ron Schrotenboer Acquisition $103.7 million Hochschild Mining Andina Minerals Stikeman Elliott - Dean Kraus, Jill Winton Fraser Milner Casgrain Acquisition $102.8 million Virgin Australia Holdings Skywest Airlines Allen & Gledhill WongPartnership Merger Undisclosed Fiat Industrial CNH Global Sullivan & Cromwell / Freshfields Bruckhaus Deringer / Legance Studio Legale Associato Cravath, Swaine & Moore / De Brauw Blackstone Westbroek / Bonelli Erede Pappalardo TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Notes Offering $3 billion Amazon.com Morgan Stanley / Goldman Sachs Davis Polk & Wardwell - Rachel Kleinberg Notes Offering $2 billion Statoil Credit Suisse / Goldman Sachs / Merrill, Lynch Sullivan & Cromwell Davis Polk & Wardwell - John Paton Notes Offering $1.5 billion Baidu JP Morgan / Goldman Sachs Skadden, Arps, Slate, Meagher & Flom / Han Kun Law / Maples and Calder / Li & Partners Davis Polk & Wardwell - John Paton Senior Notes Offering $1.25 billion CVS Caremark Barclays / Wells Fargo / Merrill Lynch / BNY Mellon / JP Morgan Davis Polk & Wardwell - Michael Mollerus, Lucy Farr White & Case External State Loan Bonds Issue $1.25 billion Ukraine Ministry of Finance JP Morgan / Morgan Stanley / VTB Capital / SIB Lavrynovych & Partners Accelerated Share Repurchase $750 million BMC Software Davis Polk & Wardwell Notes Offering $250 million Airgas Goldman Sachs / Merrill Lynch / Wells Fargo Cahill Gordon & Reindel Davis Polk & Wardwell - Rachel Kleinberg Revolving Credit Facility $190 million Ingram Micro Bank of Nova Scotia / PNC Bank / Sumitomo Mitsui / Morgan Stanley Davis Polk & Wardwell Mayer Brown Convertible Senior Notes Offering $100 million Encore Capital Morgan Stanley / Barclays Capital / Merrill Lynch Latham & Watkins Davis Polk & Wardwell - Rachel Kleinberg
  • The Australian government has announced the appointment of Teresa Dyson as chairwoman of the advisory Board of Taxation.
  • Michael Anderson KPMG has appointed Michael Anderson from Dorsey & Whitney to fill the firm's newly-created position as head of direct tax litigation in the UK. Anderson will launch the new direct tax litigation practice, adding to the firm's tax dispute resolution and investigations practices and its indirect tax litigation team.
  • Contrary to the tin-hat theories on Mayan prophecy, 2012 is over and the world has not ended. But the year has brought great change for multinationals and how they conduct their corporate tax affairs.
  • Tax partner and owner-managed business specialist Ross Welland has joined Littlejohn.
  • Zaf Kardaras has joined Northern Trust, the advisory firm covering wealth management, asset management, asset servicing and research, as tax manager for Australia and New Zealand to advise clients in the funds management and superannuation industries on financial and tax reporting.
  • The tax department at STC Partners has been strengthened by the promotions of Jérôme Talleux and Bertrand Araud.