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  • The Danish government has introduced a new measure requiring companies to expose their tax information to the public via the tax authority’s website.
  • In recent times, there has been increasing interest in the Netherlands from multinational companies that wish to avoid supposed tax havens and blacklisted jurisdictions. Roelof Gerritsen and Ivo Kuipers of Atlas Tax Lawyers put this down to the fact that the Netherlands offers more than a beneficial tax regime that encourages taxpayers to set up a Dutch holding company.
  • The Cragus Group, an independent tax adviser group in the Arabian Gulf, has boosted its practice with the appointment of Matthew Moriarty as a transfer pricing economist.
  • Taxpayers are suffering as a result of the OECD’s lack of involvement with the world’s leading emerging economies when it comes to transfer pricing.
  • Sébastien Maury and Stefan Kuhn of KPMG outline some recent, as well as contemplated, amendments of the Swiss tax law. They also explain why they think all changes and challenges will lead to an improvement of the Swiss holding location for international investors.
  • The latest developments in China’s VAT regime; how to survive a French tax dispute; and what the future holds for the US manufacturing sector under proposed tax reform were just three articles that appeared on ITR Premium last week.
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Armenia Kyrgyzstan July 24 2012 Double Taxation Avoidance Agreement (amendment) Bulgaria Switzerland July 25 2012 Double Taxation Avoidance Agreement India Indonesia July 27 2012
  • In the economic heart of Europe, Belgium is an attractive jurisdiction for combining holding activities with financing and/or intellectual property activities, explain Paul Op de Beeck and Luc Van Walleghem of KPMG.
  • Cyprus is a jurisdiction that offers many advantages for holding companies. It is often described as an offshore jurisdiction, but Boris Lazic, Michalis Zambartas and Chris Damianou of Eurofast Taxand explain that this is not the case, it simply has the benefit of having the lowest corporate income tax rate in the EU.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $15.1 billion China National Offshore Oil Company (CNOOC) Nexen Stikeman Elliott - Ron Durand, John O'Connor / Davis Polk & Wardwell Blake, Cassels & Graydon / Paul, Weiss, Rifkind, Wharton & Garrison Acquisition $3.46 billion BC Partners / The Carlyle Group United Technologies Latham & Watkins Wachtell, Lipton, Rosen & Katz Acquisition $1.7 billion NRG Energy GenOn Energy Kirkland & Ellis Skadden Arps Slate Meagher & Flom Acquisition $974 million Joh. A. Benckiser Peet’s Coffee & Tea Skadden, Arps, Slate, Meagher & Flom Cooley Merger $900 million DigitalGlobe GeoEye Skadden, Arps, Slate, Meagher & Flom Kirkland & Ellis / Latham & Watkins Acquisition $845 million Toyota Tsusho CFAO Baker & McKenzie Merger $366 million Verde Realty Brookfield Asset Management Sullivan & Cromwell - Andrew Mason, Eli Jacobson Weil Gotshal & Manges Acquisition $356 million Apple AuthenTec Weil Gotshal & Manges Alston & Bird Merger $335 million Universal Truckload LINC Logistics Latham & Watkins - John Kronsnoble Simpson Thacher & Bartlett / Mitchell, Williams, Selig, Gates & Woodyard Acquisition Undisclosed Google Sparrow Cleary Gottlieb Bredin Prat - Sébastien de Monès / Notari Selamme Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Bond Offerings $3 billion Sumitomo Mitsui Banking Goldman Sachs / Citigroup / Barclays / Merrill Lynch Davis Polk & Wardwell - John Paton Notes Offering $1 billion FedEx Goldman Sachs / J.P. Morgan / Merrill Lynch / Citigroup / Mizuho Davis Polk & Wardwell - Leslie Altus Simpson Thacher & Bartlett Equity Offering $800 million Taesa Merrill Lynch / BTG Pactual / Goldman Sachs / Santander / Banco do Brasil Paul Hastings / Souza, Cescon Avedissian, Barrieu e Flesch Advogados Davis Polk & Wardwell - Harry Ballan Junior Subordinated Debentures Offering $750 million Stanley Black & Decker Merrill Lynch / Morgan Stanley / UBS / Wells Fargo Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Po Sit Initial Public Offering $300 million Palo Alto Networks Morgan Stanley / Goldman Sachs / Citigroup Davis Polk & Wardwell - Rachel Kleinberg Common Stock Offering $106 million Kennedy-Wilson Holdings Merrill Lynch / Deutsche Bank Latham & Watkins / Kulik, Gottesman, Mouton & Siegel Davis Polk & Wardwell - Michael Farber Initial Public Offering $105 million KAYAK Morgan Stanley / Deutsche Bank Bingham McCutchen Davis Polk & Wardwell - Michael Farber