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  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Argentina Russia November 1 2012 Tax Information Exchange Agreement Bermuda Malaysia November 8 2012 Double Taxation Avoidance Agreement Canada Hong Kong November 11 2012
  • Tax directors will be called on to advise their business colleagues on some tricky structuring questions if a member of the eurozone is forced out of the currency union.
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $2.9 billion Precision Castparts Titanium Metals Stoel Rives - Christopher Heuer / O'Melveny & Myers Weil Gotshal & Manges - Jared Rusman Merger $2.8 billion Leucadia National Jefferies Group Weil Gotshal & Manges - Mark Hoenig and Chayim Neubort Wachtell, Lipton, Rosen & Katz - Jodi Schwartz, Joshua Holmes Acquisition $2.34 billion Sherwin-Williams Consorcio Comex Jones Day White & Case Acquisition $1.16 billion Corning Incorporated Discovery Labware (Becton Dickinson) Shearman & Sterling Ropes & Gray - Eric Elfman / Simmons & Simmons - Darren Oswick Acquisition $620 million Starbucks Teavana Cravath Swaine & Moore - Lauren Angelilli DLA Piper Acquisition offer $529 million Publicis Groupe LBi International Wachtell, Lipton, Rosen & Katz Acquisition $270 million AUX Galway Resources Cassels Brock & Blackwell Stikeman Elliott Acquisition $200 million SK Capital Partners Chemtura (Antioxidant and UV Stabilizers) Davis Polk & Wardwell - Neil Barr Acquisition $167 million j2 Global Ziff Davis Sullivan & Cromwell - Ronald Creamer, David Passey Acquisition Undisclosed Model N LeapFrogRx Fenwick & West - Michael Solomon, Natalie Pardo De Zela TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS SEC-Registered Debt Offering $1 billion Sasol Barclays / HSBC / J.P. Morgan Shearman & Sterling Davis Polk & Wardwell - John Paton, Alon Gurfinkel Secondary Offering $506 million MRC Global Goldman Sachs / Barclays Fried, Frank, Harris, Shriver & Jacobson Davis Polk & Wardwell - Michael Farber Cash Tender Offer for Outstanding High-Yield $200 million China Oriental Group Deutsche Bank Sullivan & Cromwell / Conyers Dill & Pearman Davis Polk & Wardwell - John Paton, Alon Gurfinkel
  • Taxpayers may have robust transfer pricing policies for their business but implementing these plans has the potential to trip-up even the most organised company.
  • Taxpayers may have appropriately robust long-term transfer pricing policies for their business on a global, regional and local basis. However, implementing these plans has the potential to trip-up even the most organised company.
  • Multinationals are under greater scrutiny than ever in Portugal following the government’s decision to create a large taxpayers unit, so it is vital taxpayers act to reduce the risk of disputes and understand their resolution options.
  • Renata Correia Cubas, of Mattos Filho, Veiga Filho, Marrey Jr e Quiroga Advogados, explains why state VAT incentives for imported goods are causing problems for Brazilian taxpayers.
  • A worrying trend is emerging for taxpayers in France, because the tax authorities are increasingly targeting foreign multinationals with French subsidiaries in tax raids.
  • Trademark licensing structures are increasingly important to multinational companies’ tax operations.
  • Dixons is leading a case along with 16 UK high street chain stores to recover VAT paid on fraudulent credit card transactions. If it wins, the precedent set could lead to a string of claims across Europe.