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  • Microsoft has taken advantage of transfer pricing to lower its effective tax rate in the US to just over half the statutory tax rate, according to its Form 10-K filing with the Securities Exchange Commission (SEC).
  • A torrent of criticism has followed the EU’s release of a transfer pricing report on developing countries.
  • Australia has released draft legislation detailing how its carbon pricing mechanism will be structured and enforced.
  • 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.
  • Pascal Saint-Amans will become director of the OECD’s Centre for Tax Policy and Administration on February 1 next year, when Jeffrey Owens retires.
  • 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?
  • 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 German Federal Ministry of Finance has extended the grandfathering clause for the application of the German Investment Tax Act (GITA) to foreign investment funds for a further two years.
  • 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
  • The knowledge of Asia’s international tax professionals is “not good enough” to cope with the rapid growth the region is experiencing, says a leading tax official.