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India’s director general for international tax and transfer pricing promises a robust interaction with various stakeholders, especially industry associations, to create a solution to contentious transfer pricing disputes in a move seen as meeting taxpayers halfway,

INDIA TAX FORUM: Stressing on the importance of a "non-adversarial" approach promised by India’s new finance minister, SK Mishra, (Joint Secretary, Foreign Tax Division & Competent Authority) acknowledged the growing tax litigation in India and promised a “uniformity in approach" among tax officials as one of the ways to bring about certainty for taxpayers.

In an exclusive interview, Guillermo Michel, Deputy Director of the Deputy Directorate General of Technical and Institutional Coordination at La Administración Federal de Ingresos Públicos (AFIP), talks to International Tax Review about recent and future compliance initiatives, the challenges the tax authority faces, inter-jurisdictional cooperation, and why it wants taxpayers to be successful in their economic activities.

Type of treaty Country Country Date signed Double Taxation Avoidance Agreement (Annex) France Oman August 27 2012 Tax Information Exchange Agreement Guernsey Italy September 6 2012 Tax Information Exchange Agreement Guernsey Latvia September 6 2012 Tax Information Exchange Agreement Austria Jersey September 7 2012 Double Taxation Avoidance Agreement Fiji UAE September 7 2012

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.6 billion Valeant Pharmaceuticals International Medicis Pharmaceutical Sullivan & Cromwell - Ronald Creamer / Skadden, Arps, Meagher & Flom Weil, Gotshal & Manges / Latham & Watkins - Nicholas DeNovio Acquisition $944.4 million Weichai Power KION Hengeler Mueller / King & Wood Mallesons Freshfields Bruckhaus Deringer / Gleiss Lutz Acquisition $767.8 million Infra-PSP Canada Grupo Isolux Corsán Lefosse Advogados / Linklaters Acquisition $300 million OTPP Manabi Minerais Lefosse Advogados Acquisition $158.5 million Warburg Pincus Endurance Energy Stikeman Elliott / Willkie Farr & Gallagher Acquisition $129.8 million Twin Butte Energy Waseca Energy Stikeman Elliott - Julie D’Avignon Acquisition $116.8 million FormFactor Astria Semiconductor Holdings (MicroProbe) Davis Polk & Wardwell - Rachel Kleinberg DLA Piper Acquisition $95 million Meda Jazz Pharmaceuticals Covington & Burling - Rob Heller Acquisition Undisclosed Franchise Services of North America Simply Wheelz Stikeman Elliott / Edinger Associates / Paul Hastings Sidley Austin / Blake, Cassels & Graydon Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $4.2 billion Banco Santander (Grupo Financiero Santander) Barclays / Citigroup / Credit Suisse / Goldman Sachs / JPMorgan / RBC Capital Davis Polk & Wardwell Shearman & Sterling

Analysis of the ECJ’s Philips ruling; opportunities in the Germany-Spain DTA; and why South Africa is unlikely to raise VAT were just three articles that appeared on ITR Premium last week.

The Internal Revenue Service (IRS) and US Treasury Department recently released final regulations under section 1248 addressing the characterisation of gain recognised by US taxpayers on the receipt of certain types of distributions from foreign corporations (the final regulations) (T.D. 9585).

Differences between the tested transaction and the comparable transaction, when applying the transactional net margin method, should be adjusted where such differences materially affect the net profit margin, in accordance with rule 10B(e)(iii) of the Income Tax Rules.

The beginning of September marked VAT increases in Spain and Israel. While Spain’s three percentage point rise was much sharper than Israel’s one percentage point increase, both are hurting taxpayers.

Poland has proposed changes to its corporate tax system, including transfer pricing amendments, bringing more transactions under the spotlight of the tax authorities.