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Chris Lenon, group strategic adviser on tax policy at Rio Tinto and chairman of BIAC’s Taxation and Fiscal Policy Committee talks to International Tax Review about the indirect tax challenges his company is facing and how it is tackling them.

The Canadian Ministry of Finance has proposed a number of changes to its tax regime, including transfer pricing amendments, of particular note is the plan to treat investments in foreign affiliates by foreign-controlled Canadian corporations as deemed dividends.

India’s taxpayers have received welcome news from the Income Tax Department that the tolerance band for transfer pricing adjustments will remain at 5% for financial year 2011 to 2012.

Swedish Prime Minister Fredrik Reinfeldt has paved the way for a corporate tax cut, saying the measure is necessary for Sweden to remain competitive.

TREATY ANALYSIS: India and Indonesia last month signed an updated version of their 1987 tax treaty.

France has amended its Finance Act to include a 3% surtax on dividend distributions, changes to the controlled foreign company (CFC) rules, and further restrictions on tax loss carryforwards.

The Tax Justice Network and CCFD-Terre Solidaire have a new report out today exploring lessons for registries of trusts and foundations and for improving automatic tax information exchange (AIE). International Tax Review talks to the report’s author, Markus Meinzer, on the deficiencies he uncovered, the positive examples he’s found and the challenges to increasing transparency over beneficial ownership.

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Canada Saint Lucia Entered into force July 20 2012 Double Taxation Avoidance Agreement Fiji UAE July 26 2012 Double Taxation Avoidance Agreement Mauritius Nigeria August 13 2012

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $3.3 billion The Carlyle Group Getty Images Debevoise & Plimpton Weil, Gotshal & Manges Joint Venture $1.36 billion BlueScope Steel Nippon Steel King & Wood Mallesons Clayton Utz Acquisition $600 million AT&T NextWave Wireless Sullivan & Cromwell Lowenstein Sandler Acquisition $546 million Royal DSM Ocean Nutrition Canada Norton Rose - Derek Chiasson McInnes Cooper Equity Financing Agreement $400 million Jefferies Group / Blackstone / GETCO / Stephens / Stifel Financial / TD Ameritrade Holding Knight Capital Group Wachtell, Lipton, Rosen & Katz - Joshua Holmes Acquisition $389 million Endeavour Mining Avion Gold Stikeman Elliott - Francesco Gucciardo Cassels, Brock & Blackwell Acquisition $300 million Investcorp Archway Marketing Services Davis Polk & Wardwell - Kathleen Ferrell Acquisition Undisclosed Odyssey Investment Partners Pexco Latham & Watkins - David Raab TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Senior Notes Offering $1.5 billion Celgene J.P. Morgan / Merrill Lynch / Morgan Stanley Proskauer Rose Davis Polk & Wardwell - Neil Barr Notes Offering $1.5 billion Texas Instruments Citigroup / J.P. Morgan / Morgan Stanley Davis Polk & Wardwell - Rachel Kleinberg Acquisition Financing $1.25 billion Campbell Soup Company Morgan Stanley / Barclays / J.P. Morgan / BNP Paribas Davis Polk & Wardwell White & Case Senior Notes Offering $700 million Nuance Communications Barclays Capital / Morgan Stanley Wilson Sonsini Goodrich & Rosati Davis Polk & Wardwell - Lucy Farr Notes Offering $500 million Praxair Credit Suisse / J.P. Morgan / Wells Fargo Cahill Gordon & Reindell Davis Polk & Wardwell - Samuel Dimon Senior Notes Offering $500 million Sinopec Group Overseas Development Goldman Sachs / Morgan Stanley / CCB International / Mizuho Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - John Paton Medium-term Note Programme $399 million AIMS AMP Capital Industrial REIT United Overseas Bank / Standard Chartered WongPartnership Allen & Gledhill Debt Tender Offer $377 million Stanley Black & Decker Citigroup Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell Hybrid Notes Offer $366 million APA King & Wood Mallesons Clayton Utz Initial Public Offering $233 million Manchester United Jefferies & Co / Credit Suisse / J.P. Morgan / Merrill Lynch / Deutsche Bank Latham & Watkins Davis Polk & Wardwell - Neil Barr

Given the complexity of the Belgian VAT regime on immovable property and the magnitude of the VAT amounts at stake, VAT has always been an important aspect in the Belgian real estate sector.