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The European Court of Justice (ECJ) has decided that HMRC’s attempts to stop Philips UK claiming group tax relief on losses transferred from a domestic permanent establishment (PE) infringed EU law.

Peru is repealing the Export of Services Promotion Act, which will hurt many Peruvian companies selling their services abroad.

The publication of the models for how FATCA could be implemented have focused minds on January 1 2013, when the phased enforcement of the legislation begins.

In welcome news for investors, the committee appointed by the Indian government to assess the merits of general anti-avoidance rules (GAAR) in the country, led by Parthasarathi Shome, has recommended delaying its implementation by three years.

With Decree no.1 of January 20 2012 (Liberalisation Decree), Italy modified its exit tax regulation in accordance with the principles contained in National Grid Indus case. Under the new rule, companies resident for tax purposes in Italy which transfer their registered office to either an EU member state, Iceland, Liechtenstein or Norway can now opt, subject to certain conditions, for a deferral of the payment of the tax due on unrealised gains.

Companies in Europe are increasingly aware of, and concerned about, the effect of tax planning exposure on their company reputation, a survey conducted by Taxand shows.

Asian countries are discussing a unified strategy to tackle transfer mispricing in the region this week.

The Indian authorities are looking at the provisions of safe harbour again, after they were initially raised in 2009.

TREATY ANALYSIS: The old double taxation avoidance agreement between Germany and Spain was signed nearly half a century ago, so it made sense when on February 3 2011, the two countries met in Madrid to sign a new treaty and protocol.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $13.4 billion China Telecom Corporation CDMA network assets Sullivan & Cromwell / Jingtian & Gongcheng / Freshfields Bruckhaus Deringer Acquisition $3.7 billion Daikin Industries Goodman Global Davis Polk & Wardwell - Avishai Shachar Simpson Thacher & Bartlett Acquisition $3.7 billion M&T Hudson City Wachtell, Lipton, Rosen & Katz Sullivan & Cromwell Acquisition $3.1 billion Scotiabank ING Direct Canada Torys Sullivan & Cromwell - Ronald Creamer / Norton Rose Acquisition $430 million Sunovion Pharmaceuticals Elevation Pharmaceuticals Latham & Watkins - Laurence Stein Acquisition $253 million Western Mining Group Inter-Citic Minerals Stikeman Elliott Miller Thomson Business Transfer Agreement $200 million Hospira Orchid Pharma Khaitan & Co / Baker & McKenzie Latham & Watkins / Amarchand, Mangaldas & Co. Acquisition Undisclosed GENIVAR Smith Carter Stikeman Elliott Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $1 billion LabCorp Credit Suisse / Merrill Lynch Hogan Lovells Davis Polk & Wardwell - Michael Farber PERLS VI Hybrid $770 million Commonwealth Bank of Australia Morgan Stanley / ANZ Securities / Goldman Sachs / Macquarie Capital / RBS / Westpac Freehills King & Wood Mallesons