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Type of Agreement Country Country Date Signed Double taxation avoidance agreement India Lithuania July 26 2011 Tax information exchange agreement Argentina Guernsey August 1 2011 Tax information exchange agreement Cayman Islands Guernsey August 1 2011

The Indonesian Tax Court recently issued a decision in relation to the allocation cost from the head office of a permanent establishment (PE) in Indonesia.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.3 billion Windstream Corporation PAETEC Holding Corporation Skadden, Arps, Slate, Meagher & Flom - Pamela Endreny Acquisition $1 billion China Investment Corporation Diamond S Shipping Sullivan & Cromwell - Ron Creamer Acquisition $860 million Ipsos SA Synovate (Aegis Group plc) Slaughter and May - Sara Luder, Ed Milliner Acquisition $742 million Archer Limited Great White Energy Services Skadden, Arps, Slate, Meagher & Flom - Sally Thurston Akin Gump Strauss Hauer & Feld Acquisition $323 million Braskem SA The Dow Chemical Company Skadden, Arps, Slate, Meagher & Flom Acquisition $72 million Cargotec Holding Netherlands (Cargotec Corporation) China Crane Investment Holdings Ltd Davis Polk & Wardwell Acquisition $52 million Direct Energie Poweo (Verbund) Bredin Prat - Sebastien de Mones, Philippe Gosset Freshfields Bruckhaus Deringer Merger Undisclosed Westwood One Inc Dial Global (Triton Media Group) Skadden, Arps, Slate, Meagher & Flom - Michael Beinus Kirkland & Ellis Acquisition Undisclosed Sodexo Lenotre Group (Accor) Davis Polk & Wardwell Allen & Overy Acquisition Undisclosed EPH (Energeticky a Prumyslovy Holding) CEZ Hengeler Mueller - Matthias Scheifele, Jurgen Nosky Acquisition Undisclosed Cube Infrastructure Fund Vinci Construction France Arsene Taxand - Denis Andres, Jacques Mestoudjian Paul Hastings - Alexis Terray Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Refinancing Undisclosed Conergy AG Freshfields Bruckhaus Deringer - Christian Ruoff, Alexander Schwahn

Microsoft’s Form 10-K filing with the Securities Exchange Commission (SEC) shows the company’s effective tax rate in the US is just over half the statutory tax rate. But how has it managed to achieve this?

The Philippines has finally issued the much-delayed revenue regulations governing the tax incentives granted to real estate investment trusts (REITs).

Canadian Finance Minister Jim Flaherty announced possible plans to close a corporate tax loophole associated with specified investment flow-through (SIFT) entities.

The 50p tax rate is a significant factor for companies in choosing where to locate and a key means of convincing people that the coalition’s deficit reduction programme is not just hitting the poor. Cracks, however, are beginning to appear between the Liberal Democrats and the Conservatives.

Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all levels of their company's tax affairs.

Kimberly Tan Majure has joined KPMG’s Washington National Tax practice as a principal in the international corporate services group.

The IRS is moving its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes, to bring them together under the Large Business & International (LB&I) Division’s international operation.