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  • European Commission President Jose Manuel Barroso said that the Libor scandal over interest rate derivatives has strengthened the case for a financial transactions tax (FTT).
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Austria Cyprus May 21 2012 Tax Information Exchange Agreement Bahrain India May 31 2012
  • The Maltese Labour Party and the Malta Business Bureau have rejected the EU’s proposal for a common consolidated corporate tax base (CCCTB), saying it could damage the country’s economic interests.
  • Anders Borg, Sweden’s finance minister, has reiterated that the country’s corporate tax rate may be lowered.
  • Previously, capital gains, realised by resident and non-resident individuals on transfer of privately-held Austrian real estate sold after a 10-year holding period, were exempt from Austrian taxation.
  • Peggi Rockefeller has joined Vertex, the leading provider of corporate enterprise tax solutions, as chief tax officer, US transaction tax.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $3.08 billion CGI Group Logica Sullivan & Cromwell - Michael McGowan Freshfields Acquisition $900 million Marfrig Cargill Lefosse Acquisition $600 million Jackson National Life Insurance Swiss Re (REALIC) Skadden, Arps, Slate, Meagher & Flom Sullivan & Cromwell Acquisition $220 million AngloGold Ashanti Kinross Gold (Crixas gold mine) Stikeman Elliott Spin-Off Sears Canada Sears Holdings Corporation Torys Osler, Hoskin & Harcourt / Simpson Thacher & Bartlett Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $1.25 billion Covidien BNP Paribas / Citigroup / Deutsche Bank Gibson, Dunn & Crutcher Davis Polk & Wardwell - Michael Mollerus Initial Public Offering $1.02 billion PIMCO Dynamic Income Fund Morgan Stanley / Citigroup / Merrill Lynch / UBS / Wells Fargo Ropes & Gray Davis Polk & Wardwell - Rachel Kleinberg Notes Offering $500 million Energizer Goldman Sachs / J.P. Morgan / Merrill Lynch Bryan Cave Davis Polk & Wardwell - Samuel Dimon Senior Secured Notes Offering $250 million Momentive Performance Materials J.P. Morgan Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell Share Offer $200 million Ten Network Citigroup Freehills / Sidley Austin King & Wood Mallesons
  • India’s finance minister, Pranab Mukherjee, has said that tax cases settled before April 1 will not be reopened, in a move which aims to allay investor fears over the retroactive amendment announced in March’s budget, though advisers warn investors that the statement is superficial.
  • The Ghanaian government has indicated in a letter to IMF managing director Christine Lagarde that it expects to bring in as much as $165 million from the increased corporate tax rate on mining firms.
  • As the economic situation in Europe remains uncertain, taxpayers are facing increasing numbers of audits from revenue-hungry authorities. Coupled with a potential break-up of the currency, it is important that taxpayers make certain provisions in their transfer pricing departments. Two tax executives, including the European head of tax for Siemens, the German multinational, discuss how they approach adjustments and how they view the euro’s future in terms of transfer pricing.