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Sonya Manzor, of William Fry, analyses the Irish Supreme Court’s first GAAR ruling and what it means for non-commercially driven tax planning.

The Hut is the latest company to be exposed for dodging the UK’s low value consignment relief (LVCR) removal on Channel Islands mail order. But neither advisers nor campaigners see the merits in circular shipping via the US.

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

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

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.

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.

IRS commissioner Doug Shulman bows out emphasising compliance successes; Amazon, Google and Starbucks grilled over UK tax affairs; Dixons ECJ case to recover VAT on fraudulent credit card transactions could trigger claims across EU; and How multinationals can prepare their French subsidiaries for tax raids

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.

Trademark licensing structures are increasingly important to multinational companies’ tax operations.

A worrying trend is emerging for taxpayers in France, because the tax authorities are increasingly targeting foreign multinationals with French subsidiaries in tax raids.