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  • Taxpayers in the emerging BRIC economies need to be aware that face-to-face interaction with officials will reduce the length of transfer pricing disputes, says panel.
  • Delegates at International Tax Review's Global Transfer Pricing Forum in London last week had many questions and concerns about transfer pricing that ranged from intangibles to financial transactions.
  • Type of Agreement Country Country Date Signed Tax information exchange agreement China Cayman Islands September 26 2011 Double taxation avoidance agreement Russia Switzerland September 25 2011
  • Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Notes offering $5 billion Intel Corporation Citigroup Global Markets; Goldman Sachs; Merrill Lynch Gibson, Dunn & Crutcher Davis Polk & Wardwell - Rachel Kleinberg, Una Au Global bond offering $2 billion Province of Ontario Barclays Bank; Merrill Lynch; Goldman Sachs; RBC Capital Markets Davis Polk & Wardwell Notes offering $2 billion Rio Tinto Barclays Capital; BNP Paribas; Morgan Stanley; Citigroup; HSBC Securities Davis Polk & Wardwell - John Paton, Adam Perry Senior unsecured notes offering $1.2 billion Xylem JP Morgan; RBS Securities; Wells Fargo Securities Simpson Thacher & Bartlett Davis Polk & Wardwell Global bond offering $750 million Province of British Columbia Merrill Lynch, Pierce, Fenner & Smith; CIBC World Markets Corp; HSBC Securities; RBC Capital Markets Davis Polk & Wardwell Senior unsecured notes offering $650 million Exelis Barclays Capital; Citigroup Global Markets; JP Morgan Securities Simpson Thacher & Bartlett Davis Polk & Wardwell Notes offering $400 million Kansas City Power & Light Barclays Capital; RBS Securities; Wells Fargo Securities Dewey & LeBoeuf Davis Polk & Wardwell - Rachel Kleinberg, Una Au
  • Chancellor George Osborne has been given clearance by the European Commission to expand the Enterprise Investment Scheme (EIS) by increasing the tax breaks available to companies that qualify. The expansion has been valued at £100 million ($155 million).The Treasury this week stated that high growth companies have created over 54% of all jobs in companies with more than 10 members of staff. The new measures are planned for implementation in April 2012 as the government seeks to spark life into the economy and support private sector growth.
  • French law firm, FTPA, has expanded into tax with the appointment of Nicolas Message as partner.
  • Australia has made changes on the taxation of trusts a year after a high court ruling found uncertainties and longstanding problems with the country’s tax law.
  • Week eight of the Supreme Court hearing saw the tax department begin their arguments by claiming that the sale of the share from the Cayman Islands company was nothing but an “artificial tax avoidance scheme”.
  • A panel of advisers, taxpayers and government officials, at International Tax Review’s 11th Global Transfer Pricing Forum last week, discussed the challenges involved in dealing with financial transactions.
  • Giving the keynote address to Green Budget Europe’s annual conference, hosted by the European Environment Agency in Copenhagen, Connie Hedegaard, EU Climate Action Commissioner, called for binding targets and a shift from tax on labour to environmental taxation.