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In a binding private ruling, the South African Revenue Service (SARS) has concluded that a non-resident company, whose effective management is not in South Africa, does not constitute a permanent establishment (PE).

The Bozzer decision offers new hope for reducing arrears and deficiency interest and penalties in transfer pricing and tax avoidance disputes.

Trading began May 30 on the Mercado Integrado Latinoamericano (MILA) stock exchange, which allows cross-border trading between Peru, Colombia and Chile. Yet the three countries’ disparate tax laws may hinder investment and trading on the new bourse.

Type of Agreement Country Country Date Signed Double taxation avoidance agreement India Tanzania May 28 2011 Double taxation avoidance agreement Hong Kong Czech Republic June 6 2011

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.3 billion Sealed Air Corporation Diversey Holdings Inc Simpson Thacher & Bartlett Skadden, Arps, Slate, Meagher & Flom Acquisition $1.025 billion NBCUniversal Universal Orlando (Blackstone Group) Davis Polk & Wardwell - Avishai Shachar, Neil Barr, Kay Ng, Patrick Sigmon Skadden, Arps, Slate, Meagher & Flom Acquisition of ownership interest $500 million Fiat Chrysler Group (US Treasury stake) Sullivan & Cromwell - Andrew Solomon Acquisition $464.5 million Mongolian Mining Corporation Quincunx (BVI) Ltd Millbank, Tweed, Hadley &McCloy Davis Polk & Wardwell - Kathleen Ferrell, Adam Perry Merger $71.4 million BankUnited Inc Herald National Bank Skadden, Arps, Slate, Meagher & Flom - Stuart Finkelstein Sandler O'Neill & Partners; Luse Gorman Pomerenk & Schick, PC Acquisition Undisclosed Schneider Electric Telvent GIT SA Bredin Prat Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Acquisition financing $4.5 billion Caterpillar Inc JP Morgan Securities; Barclays Capital Inc; RBS Securities Inc Sidley Austin Davis Polk & Wardwell - Kathleen Ferrell, Aharon Illouz SEC-registered debt offering $1.75 billion Applied Materials Inc JP Morgan Securities; Citigroup Global Markets; Mitsubishi UFJ Securities; Morgan Stanley Davis Polk & Wardwell - Rachel Kleinberg, Ryan LaRosa Initial public offering $1.4 billion Yandex NV Morgan Stanley&Co; Deutsche Bank Securities Inc; Goldman, Sachs & Co. Wilmer Cutler Pickering Hale & Dorr; Van Doome NV; Laseta Partners Davis Polk & Wardwell - John Paton, Alon Gurfinkel Credit agreement $1.05 billion The AES Corporation Bank of America NA Davis Polk & Wardwell - Michael Mollerus, Gregory Hannibal Shearman & Sterling Public notes offering $500 million Aon Corporation Morgan Stanley & Co Inc; Merrill Lynch, Pierce, Fenner & Smith Inc Davis Polk & Wardwell - Samuel Dimon, Aharon Illouz Public notes offering $250 million Airgas Inc Goldman, Sachs & Co; Merrill Lynch, Pierce, Fenner & Smith; Wells Fargo Securities Cahill Gordon & Reindel Davis Polk & Wardwell - Rachel Kleinberg, Jason Chlipala Initial public offering $227 million Solazyme Inc Morgan Stanley & Co; Goldman, Sachs & Co Davis Polk & Wardwell - Rachel Kleinberg, Ryan LaRosa Wilson, Sonsini, Goodrich & Rosati Term and revolving facilities $205 million Workspace Group Royal Bank of Scotland Slaughter & May - Mike Lane, Max Mittasch

Egyptian finance minister, Samir Radwan, has outlined a new capital gains tax (CGT) of 10% in the first draft budget since Hosni Mubarak was ousted by the February revolution.

Greek plans to cut VAT rates to 20% only a year after two rises to 23% show that it has yet to find the right tax strategy to stabilise its ailing economy.

Christian Aid wants the UK government to change the terms of a tax deal it is negotiating with Switzerland.

DLA Piper – the world’s largest law firm by attorney headcount – has recruited former global tax planning committee chair Gerald Rokoff from White & Case.

Indian firm, BMR Advisors - Taxand, has announced its new leadership structure including the promotion of Mukesh Butani to the role of chairman of the firm.