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  • Switzerland is determined to remain a highly desirable place for multinationals to do business, regardless of EU pressure on its system of cantonal corporate taxation.
  • The UK Treasury has today released details on its plans to reform its controlled foreign companies (CFC) rules as well as issuing details on the country’s new patent box.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $18.6 billion United Technologies Corporation Goodrich Corporation Davies Ward Phillips & Vineberg LLP; Wachtell, Lipton, Rosen & Katz Jones Day Acquisition $3.6 billion Verizon Wireless Comcast Corporation Davis Polk & Wardwell - Mary Conway, Ethan Goldman Davis Polk & Wardwell - Avishai Shachar, Neil Barr, Kay Ng Acquisition $3.4 billion SAP SuccessFactors JP Morgan Chase Fenwick & West - Ron Schrotenboer, Zach Jones Merger $2.3 billion PAETEC Holding Corp. Windstream Corporation Hogan Lovells - Daniel M. Davidson, Scott D. McClure, Inga Rubin Skadden, Arps, Slate, Meagher & Flom LLP Acquisition $645 million Heineken International B.V. Galaxy Pub Estate (from RBS) Freshfields Bruckhaus Deringer - Sarah Falk Sapient Corporate Finance Cross-border merger Undisclosed Deutsche Bank ZRt. (Hungary) Deutsche Bank (Portugal) S.A. Hengeler Mueller Hengeler Mueller Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Five-year banking facility $845 million Ladbrokes Plc. Slaughter and May - Richard Levitt, Gareth Miles Notes offering $500 million Banco do Brasil BB Securities Ltd, Banco Bradesco BBI S.A., Citigroup; HSBC; J.P. Morgan Clifford Chance US LLP, Campos Mello Advogados, Ogier Davis Polk & Wardwell - Maurice Blanco, Coutenay U. Myers Notes offering $500 million Canadian Pacific Railway Company J.P. Morgan Securities LLC Paul, Weiss, Rifkind, Wharton & Garrison LLP, Macleod Dixon LLP Davis Polk &Wardwell - Harry Ballan Public offering $200 million Netflix, Inc. Morgan Stanley & Co. LLC, J.P. Morgan Securities LLC Wilson Sonsini Goodrich & Rosati Davis Polk & Wardwell - Bruce K. Dallas, Alan F. Denenberg
  • An Indian high court has ruled that income from the sale of shrink-wrapped software is a royalty and therefore taxable.
  • WTP Advisors has announced that Guy Sanschagrin, previously a PwC director, has joined its transfer pricing practice, based in Minneapolis.
  • The UK Treasury today released draft legislation on the creation of a patent box for intellectual property (IP) management.
  • Werner Stuffer has joined Ernst & Young Terco in Brazil as head of the transfer pricing practice and European inbound business. He was formerly at PwC in Germany and before that worked for Siemens for more than 12 years, where he finished as vice-president, international tax.
  • Norway’s Supreme Court has ruled that Dell Products, a Norwegian commissionaire company, does not constitute a sales agency permanent establishment (PE) in Norway.
  • Indirect tax specialists from India and around the world have urged the government in Delhi to get the design of its dual GST system correct before thinking about introducing it.
  • Carbon tax in Ireland will rise by €5-€10 ($7-$13) per tonne in next week’s budget but the hike has been criticised for being too low.