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The European Court of Justice (ECJ) handed down its judgment in the Accor case [C-310/09] on September 15. The judgment represents a complete victory for Accor and has a significant impact on other pending cases involving dividend taxation.

A court case on debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines.

The European transfer pricing panel, on day one of International Tax Review’s Global Transfer Pricing forum yesterday, was boosted by revenue officials from the Netherlands, Spain and France.

Krister Andersson, chairman of the tax policy group at Business Europe, opened the second day of International Tax Review’s 11th annual Transfer Pricing Forum with an overview of the changes to the tax landscape and how this is affecting the business community.

A panel of experts at International Tax Review’s 11th annual Transfer Pricing Forum said there is a lot of positivity around the advance pricing agreement (APA) programme in the UK, and complimented the UK tax authorities for their commitment to the programme.

Representatives from various factions of the OECD discussed the projects on intangibles and the administrative aspects of transfer pricing at International Tax Review's 11th Global Transfer Pricing Forum.

Taxpayers need to be aware that transfer pricing joint audits are just around the corner and should begin preparing for them now, says a panel of leading experts.

Giving his keynote address to International Tax Review's 11th Global Transfer Pricing Forum, Dave Hartnett, permanent secretary for tax at HM Revenue & Customs (HMRC), drew on lessons learned from the OECD's Forum on Tax Administration, which looks at practical issues of transfer pricing for tax administrations.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $200 million National Express Group Petermann Partners Davis Polk & Wardwell; Gardere Wynne Sewell Acquisition $16.1 million Natus Medical Embla Systems Fenwick & West - Ron Schrotenboer Acquisition Undisclosed Blackstone Mint Hotels Freshfields Bruckhaus Deringer - Helen Lethaby, Todd Kramers, Paul Concannon Acquisition Undisclosed Didier Ferre (Ferre Hotels) Concorde Montparnasse (Starwood Capital) Landwell & Associes Davis Polk & Wardwell - Jacques Naquet-Radiguet, Julie Herzog Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) SEC-registered debt offering $1 billion The Export-Import Bank of Korea Credit Suisse Securities; Daiwa Capital Markets Europe; Goldman Sachs International Davis Polk & Wardwell - John Paton, Sarah Joy Notes offering $700 million HJ Heinz Company JP Morgan Securities; BNP Paribas Securities; HSBC Securities Davis Polk & Wardwell - Samuel Dimon, Adam Perry Sullivan & Cromwell SEC-registered notes offering $500 million Fluor Corporation Merrill Lynch, Pierce, Fenner & Smith; BNP Paribas Securities Jones Day Davis Polk & Wardwell - Samuel Dimon, Nicole Field Rule 144A offering $350 million Banco de Credito del Peru (BCP) Davis Polk & Wardwell - Michael Mollerus, Michael Bretholz Millbank, Tweed, Hadley & McCloy

Type of Agreement Country Country Date Signed Tax information exchange agreement Guernsey Czech Republic September 20 2011 Tax information exchange agreement Guernsey Bahamas September 20 2011