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  • UK finance minister George Osborne should not be using today’s visit to his Indian counterpart to complain about the Indian tax system, he should be patting him on the back and telling him to keep up the good work.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) All-share Merger $61.9 billion Xstrata Glencore International King & Wood Mallesons King & Wood Mallesons Acquisition $2 billion Guggenheim Baseball Management Los Angeles Dodgers Foley & Lardner Sullivan & Cromwell Strategic Partnership $2 billion Mubadala Development EBX Group Shearman & Sterling Davis Polk & Wardwell - Kathleen Ferrell, Michelle Messer, Arie Rubenstein Acquisition $681.7 million PetroChina Athabasca Oil Sands (MacKay River) Stikeman Elliott Acquisition $500 million Bausch & Lomb ISTA Pharmaceuticals Cleary Gottlieb Steen & Hamilton Davis Polk & Wardwell / Greenhill & Co. Acquisition $380.2 million ISPT CFS Retail Property Trust Holding Redlich King & Wood Mallesons Acquisition $173 million Monitise Clairmail Sullivan & Cromwell Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Five-Year Revolving Credit Facility $1.5 billion Aetna J.P. Morgan / Citigroup / Merrill Lynch Davis Polk & Wardwell Cravath, Swaine & Moore Ordinary Shares Offering $1.2 billion Michael Kors Holdings Morgan Stanley / J.P. Morgan / Goldman Sachs Paul, Weiss, Rifkind, Wharton & Garrison / Harney Westwood & Riegels Davis Polk & Wardwell - Mary Conway, Lauren Murphey Refinancing Senior Secured Term Loans $1.2 billion Rovi J.P. Morgan / Morgan Stanley Cooley Davis Polk & Wardwell - Rachel Kleinberg, Arie Rubenstein Notes Offering $750 million Syngenta Finance Citigroup / Merrill Lynch Sidley Austin / Davis Polk & Wardwell - John Paton, Alon Gurfinkel De Brauw Blackstone Westbroek / Homburger Initial Public Offering $575 million Vantiv J.P. Morgan / Morgan Stanley / Credit Suisse Weil, Gotshal & Manges Davis Polk & Wardwell - Harry Ballan, William Curran, Kerry Price
  • On December 28 2011, the Indonesian Directorate General of Taxes (DGT) issued Regulation No. PER-43/PJ/2011 setting out the new criteria for determining tax residency.
  • When allocating corporate costs for intra-group services, the Norwegian Tax Authorities has in recent years been claiming that allocations based on opex/capex must be adjusted for local price- and cost levels by applying a price level indicator (PLI). Jan Jansen and Joachim Bjerke of BA-HR explain what this means for the Norwegian energy sector.
  • The adoption of new accounting standards based on IFRS as of 2008, and the effects of such new rules for Brazilian taxpayers, is among the most relevant tax matters under discussion in Brazil, explain Paulo Rogerio Sehn and Simone Dias Musa of Trench, Rossi e Watanabe Advogados.
  • The trend for greater collection looks set to continue in China In 2010, China collected a record amount of tax from non-resident enterprises. That momentum for growth was expected to continue in 2011, and recent figures confirm this.
  • Back in January, the European Commission launched a public consultation on the double non-taxation of cross-border companies. The Commission hopes the consultation will gauge the full scale of the problem and see where the main weaknesses lie and will develop a policy response before the end of 2012. Jack Grocott speaks to Philip Kermode, Director for Direct Taxation in DG Taxation and Customs, about what he hopes the consultation will achieve and what it means for taxpayers.
  • The OECD’s Centre for Tax Policy and Administration (CPTA) faced an uncertain future last year when three of its high-level officials left. The candidates that have taken on the task of directing tax and transfer pricing policy have brought with them an air of calm, however, that has settled the turbulent waters at a crucial time for transfer pricing policy with their boundless enthusiasm and experience. Sophie Ashley speaks to Marlies de Ruiter, the new head of the Tax Treaties, Transfer Pricing and Financial Transactions division in her first month on the job.
  • The interactions between taxpayers and officials in Latin America can often be fiery, but continual efforts are being made to improve such relationships. Matthew Gilleard speaks to advisers from across the region to gauge how things are progressing and whether the officials are doing enough.
  • Suddenly finding yourself without a key part of your tax department can be a problem at the best of times, particularly in the middle of a major international merger. Salman Shaheen explores how taxpayers can benefit from interim VAT management in emergency situations and how it differs from companies’ more common experience of secondment.