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IBM’s 2010 Global Locations Trends report ranked Ireland 1st in global inward investment per capita. This is a continuation of its ranking in previous years. Conor O’Sullivan of KPMG describes the factors that make it competitive to exploit IP in Ireland

Intangible transactions are one of the most challenging topics in the transfer pricing area, not only from a theoretical perspective but also because of the increasing number and size of the disputes regarding their recognition and valuation. Oliver Wehnert and Jakob Frotscher of Ernst & Young provide an outline of the major challenges in the identification and valuation of intangible assets

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $4.5 billion SCBT Financial Corporation Peoples Bancorporation Wachtell, Lipton, Rosen & Katz - Joshua Holmes Scott & Stringfellow; Haynsworth Sinkler Boyd Acquisition $2.7 billion Tokio Marine Holdings Delphi Financial Group Sullivan & Cromwell - Robert DeLaMater, Melissa Sawyer, Izumi Akai & Keiji Hatano Cravath Swaine & Moore, Morris; Nichols, Arsht & Tunnell Acquisition $1.3 billion Pacific Metals Company Strand Minerals (Eramet) Davis Polk & Wardwell - Tyler Carson & Emilie Huard Acquisition $338 million Thales DCNS Bredin Prat - Olivier Rogivue & Sophie Cornette de Saint-Cyr Acquisition $325 million Macquarie Infrastructure Partners II WCA Waste Corporation Davis Polk & Wardwell Mayer Brown Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Amendment and Restatement of Secured Credit Facilities $1.75 billion Quicksilver Resources J.P. Morgan Securities, Merrill Lynch, Bank of Nova Scotia Davis Polk & Wardwell - Michael Mollerus & Kerry Price Simpson Thacher & Bartlett; Blake, Cassels & Graydon Initial Public Offering $1 billion Michael Kors Holdings Morgan Stanley, J.P. Morgan Securities, Goldman Sachs Paul, Weiss, Rifkind, Wharton & Garrison; Harney Westwood & Riegels Davis Polk & Wardwell - Mary Conway & Lauren Murphey Rights Issue $764 million K-REIT DBS Bank, United Overseas Bank WongPartnership - Rachel Eng, Long Chee Shan & Karen Yeoh Clifford Chance - Raymond Tong & Bin Wen Shern Debut Global Offering $600 million Banco de Bogotá S.A Davis Polk & Wardwell - Harry Ballan & Juelle Gomes Multicurrency MTN Programme $387 million United Engineering HSBC Overseas Chinese Banking Corporation Wong Partnership - Hui Choon Yuen

Through the enactment of law 26692, the software promotional regime, created by law 25922, has been extended from September 2014 until the end of 2019.

On November 11 2011, the European Commission (EC) outlined its 2012 strategy for combating double taxation and double non-taxation in the EU.

Spain has concluded 83 tax treaties. There are 12 more tax treaties that have already been initialled or are awaiting parliamentary approval: Armenia, Azerbaijan, Belarus, the Dominican Republic, Hong Kong, Kuwait, Namibia, Nigeria, Peru, Senegal, Singapore and Syria.

On September 23, President Obama released draft legislation for economic growth and deficit reduction. Provisions that could increase taxes on multinational corporations are an important part of the plan. The plan includes the following international tax proposals:

In a case brought by the European Commission (EC) (C-284/09 Commission v. Germany, judgment of October 20 2011), the European Court of Justice (ECJ) held that Germany’s withholding tax on dividends to other corporations is in breach of community law in that it discourages persons from abroad from investing in Germany.

In October 2011, major Finnish trade unions and employers’ organisations agreed on the conditions of a new framework agreement. To support the tendencies of both parties, the Finnish government made suggestions regarding amendments in corporate and individual taxation.

On August 19 2011, the Canadian Department of Finance released a package of proposed amendments including significant changes to the tax rules governing the taxation of income earned by foreign affiliates of Canadian taxpayers.