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France has made considerable changes to its corporate tax system after the country’s parliament approved the 2011 Amended Finance Law.

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.

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.

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

The Dutch government has released its tax plans for 2012 with changes to the rules on the deductibility of interest and the treatment of foreign permanent establishments topping the bill.

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

GlaxoSmithKline (GSK) has filed its case facts with the Supreme Court of Canada refuting arguments made by the Crown in this precedent-setting transfer pricing case, involving the price of the active ingredient used to make the drug sold under the brand name Zantac.

International Tax Review's 11th annual Global Transfer Pricing Forum opens tomorrow at 9am.

The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday.