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  • The UK Treasury has pledged £77 million ($124 million) to HM Revenue & Customs (HMRC) to tackle tax avoidance by large multinationals over the next two years.
  • 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 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.
  • 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).
  • 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 Australian government has announced the appointment of Teresa Dyson as chairwoman of the advisory Board of Taxation.
  • McPartland is asking FTSE 100 companies to commit to greater tax transparency
  • Taxpayers should be aware that more and more African jurisdictions have legislated against the tax-free indirect disposal of investments. However, there are other options, explain Stephen Hales and Leon Steenkamp of Ernst & Young.
  • With the global economy in tatters and little hope in sight of change, 2013 is set to be a year of revolution for tax policies around the world.
  • Rate reduction and base broadening are two trends that taxpayers have become familiar with over the last 20 years, and while this is set to continue, 2013 will see tax evasion and avoidance thrust firmly under the spotlight. At the same time, many governments are setting out attractive tax policies aimed at stimulating investment. Finding the right balance between tax planning, compliance and transparency will be a key test for taxpayers next year. Matthew Gilleard looks at the anti-avoidance issues taxpayers must be aware of, and why greater international tax cooperation is inevitably on the way.