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The long-awaited draft UK controlled foreign companies (CFC) legislation was published in December 2011 with additional guidance and updated draft legislation issued on January 31 2012. The proposed rules affect transfer pricing by placing a new emphasis on significant people functions.

Credit rating downgrades may be worrying, but German chancellor Angela Merkel and other European leaders must resist hasty tax policy changes.

Foreign investors using Luxembourg holding companies to buy French real estate must restructure their investments or face a significantly increased tax bill, because of imminent amendments to a tax treaty between the two countries.

President Barack Obama delivered his 2013 budget speech yesterday and despite not dealing with comprehensive reform of the tax code – proposals for which will come in the next few weeks – he reiterated the sentiments of his State of the Union address and called for ending tax breaks for companies that ship jobs overseas, replacing them with incentives for those companies that conversely bring jobs and investment to the US.

The Obama Administration released the proposed Fiscal Year 2013 Budget of the US government yesterday. Aaron Bone and Katherine Kimball, of Charles River Associates in San Diego, provide a commentary on its transfer pricing implications.

With Barack Obama’s administration having announced that broad corporate tax reform will be dealt with separately in the coming weeks, and political turmoil stifling progress on US tax issues in general, there were no great expectations for the President’s 2013 budget, delivered today. But amid Obama’s rhetoric of hope and camaraderie, of fairness and responsibility, some meaningful tax changes were proposed.

Rumours of delays in the implementation of India's Direct Taxes Code (DTC) and goods and service tax (GST) should be welcomed by taxpayers.

Last month’s Vodafone ruling provided some clarity on the taxability of indirect transfers of Indian assets. But there are still some questions to be answered. Sanjay Sanghvi and Suraj Shetty of Khaitan & Co look at the Aditya Birla tax controversy in light of the Vodafone ruling and explain that the clues are there on how the country is targeting indirect transfers.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $1.9 billion Oracle Taleo Dewey & LeBoeuf Wilson Sonsini Goodrich & Rosati Acquisition $1.7 billion Hutchison 3G Orange Austria J.P. Morgan Morgan Stanley Acquisition $1.14 billion AltaGas SEMCO Stikeman Elliott Cravath, Swaine & Moore Acquisition $570 million BB&T Crump Group Debevoise & Plimpton Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $5 billion Facebook Morgan Stanley / J.P. Morgan / Goldman Sachs / Merrill Lynch / Barclays/ Allen & Co Fenwick & West Simpson Thacher & Bartlett Notes Offering $2.5 billion IBM Credit Suisse / Merrill Lynch / Mizuho / Morgan Stanley / RBC / Wells Fargo Davis Polk & Wardwell - Michael Mollerus, Ethan Goldman Notes Offering $1 billion Limited Brands Merrill Lynch / J.P. Morgan / Citigroup Davis Polk & Wardwell - Neil Barr, Arie Rubenstein Cahill Gordon & Reindel Notes Offering $600 million Praxair Citigroup / HSBC / Merrill Lynch Davis Polk & Wardwell - Samuel Dimon, Patrick Sigmon Initial Public Offering $200 million U.S. Silica Holdings Morgan Stanley / Merrill Lynch / Jefferies & Co Kirkland & Ellis Davis Polk & Wardwell - Kathleen Ferrell, Nicole Field Initial Public Offering $128 million AVG Technologies Morgan Stanley / J.P. Morgan / Goldman Sachs / Allen & Co / Cowen and Co / JMP Davis Polk & Wardwell - Menlo Park, Rachel Kleinberg, Una Au Wilson Sonsini Goodrich & Rosati / Freshfields Bruckhaus Deringer

India’s Supreme Court will begin hearing the case of E*Trade Mauritius on Friday. The case relates to the taxation of capital gains arising from the transfer of shares from a Mauritius to an Indian company.