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  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $7.6 billion Alibaba Group Holding Limited Alibaba (Yahoo!) Sullivan & Cromwell Acquisition $1.03 billion JSC Russian Railways PSA Peugeot Citroën (GEFCO) Freshfields Bruckhaus Deringer Bredin Prat - Yves Rutschmann Acquisition $977 million PTT Mining Sakari Resources Allen & Gledhill WongPartnership Acquisition $279 million Teleflex LMA International WongPartnership / Simpson Thacher & Bartlett Shearman & Sterling / Allen & Gledhill Share Subscription Deed $237 million Shandong Gold Focus Minerals Minter Ellison King & Wood Mallesons Acquisition $137 million Wesco Aircraft Holdings Interfast Latham & Watkins / Stikeman Elliott Gowlings Lafleur Henderson Acquisition $130 million Kohlberg Kravis Roberts & Co. / Beecken Petty O’Keefe & Company / Coastwood Senior Housing Partners Sunrise Senior Living Management Company Wachtell, Lipton, Rosen & Katz - T. Eiko Stange Partnership Agreement $118 million Synutra Sodiaal Davis Polk & Wardwell Cleary Gottlieb Steen & Hamilton Acquisition Undisclosed KRG Capital Convergint Technologies Hogan Lovells - Daniel Davidson, Stephen Giordano / Stikeman Elliott - Marie-Andrée Beaudry, Éric Lévesque Jones Day Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) "Covered Bonds Offering " $2.5 billion Royal Bank of Canada Morgan Stanley / RBS Morrison & Foerster / Sullivan & Cromwell Allen & Overy / Davis Polk & Wardwell "SEC-Registered Notes Offering " $2 billion RBS RBS Securities / Citigroup / Wells Fargo / BMO / BNY Mellon / CIBC / HSBC / nabSecurities / RBC / TD Securities / UBS Davis Polk & Wardwell - John Paton Shearman & Sterling Vendor Financing $1.2 billion Telefónica China Development Bank / Industrial and Commercial Bank of China Uría Menéndez / White & Case / De Brauw Blackstone Westbroek Notes Offering $1.15 billion Mexichem White & Case / Davis Polk & Wardwell - Michael Farber, Yuliya Epifantseva Cleary Gottlieb Steen & Hamilton / Ritch Mueller Notes Offering $1 billion DBS Bank BNYM WongPartnership Schedule B Debt Offering $750 million The Korea Development Bank Credit Suisse / HSBC / J.P. Morgan Securities / Morgan Stanley / RBS Cleary Gottlieb Steen & Hamilton / Jipyong & Jisung Davis Polk & Wardwell - John Paton Senior High-yield Bond Issue $150 million Sound Global Deutsche Bank / HSBC Troutman Sanders / WongPartnership Sidley Austin / Zhong Lun
  • Carbon taxes are on the rise across the world, but the sensible business will see the benefits, not just the costs.
  • The UK removed low value consignment relief (LVCR) from mail order goods earlier this year to prevent VAT abuse, but supply chain management company Euro Fulfilment is soliciting business from the UK music industry by shipping via Spain to get around it.
  • In a fast-paced business world, with constantly evolving group operational structures and trading relationships, how long does an arrangement really remain unchanged?
  • The Ghanaian Parliament has adopted transfer pricing regulations to combat the "inadequate" taxation of transactions between related enterprises.
  • Robert Waterson, of Dorsey & Whitney, examines Advocate General Kokott’s opinion in the Grattan case last week, and explains why it is bad news for taxpayers relying on the principle of fiscal neutrality.
  • A case involving a number of Ford Motor Company defined benefit (DB) pension funds was heard by the European Court of Justice (ECJ) last week, with an annual £100 million in VAT at stake.
  • A constant issue faced by multinational taxpayers is whether branches or subsidiaries are a more useful and flexible part of the corporate structure and in what circumstances it is appropriate to employ one over the other.
  • More work is required before an amendment to IAS 12, the international accounting standard that deals with accounting for income taxes, is finalised, says EFRAG, the body that advises the European Commission on the technical quality of international financial reporting standards (IFRS).
  • The European Court of Justice (ECJ) ruled that the UK’s loss relief rules for branches infringe EU law in the Philips Electronics case this month, raising the opportunity for similarly structured groups to bring claims. But the case could have knock-on effects for other taxpayers and open up new lines of attack for taxpayers in future loss relief cases.