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WTP Advisors, in the US, has acquired the transfer pricing and international structuring business of Michael J Flaherty. Under the terms of the acquisition, the new division will be named WTP Cross Border and will be led by Michael Flaherty.

The Irish Revenue Commissioners has confirmed that a small number of transfer pricing audits will take place later this year.

Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India.

By Daniel Rybnik of EnterPricing

The world’s attention has turned to Pakistan after the killing of Osama bin Laden, but companies will be keeping an eye on the country for different reasons as it considers introducing transfer pricing documentation requirements in the upcoming budget.

A US appellate court has affirmed a Tax Court ruling on the nature of guarantee fees.

The OECD is inviting public comment on the meaning of beneficial ownership due to the number of differing interpretations by courts and tax administrations.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $6.8 billion Teva Pharmaceutical Industries Ltd Cephalon Inc Kirkland & Ellis Skadden, Arps, Slate, Meagher & Flom Acquisition $645 million Silver Lake Partners and Silver Lake Sumeru SMART Modular Technologies Inc Simpson Thacher & Bartlett Davis Polk & Wardwell - Rachel Kleinberg, Ryan LaRosa Acquisition $600 million Aetna Inc Prodigy Health Group Davis Polk & Wardwell - Harry Ballan, William Curran Merger Undisclosed Exelon Constellation Skadden, Arps, Slate, Meagher & Flom - Louis Freeman Kirkland & Ellis Acquisition Undiclosed EOS Group Credirec Bredin Prat - Yves Rutschmann, Magali Buchert Paul Hastings Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) SEC-registered US Shelf facility $5 billion Abbey National Treasury Services plc Santander UK plc Slaughter & May - Sara Luder, James Wood Cleary Gottlieb Steen & Hamilton Senior notes offering $2.5 billion Abbey National Treasury Services plc Credit Suisse; JP Morgan; Santander; UBS Slaughter & May - Sara Luder, James Wood Cleary Gottlieb Steen & Hamilton Senior secured credit facility $1.855 billion C-BASS (Credit-Based Asset Servicing and Securitisation) JP Morgan Chase Bank Hunton & Williams Davis Polk & Wardwell - Kathleen Ferrell, Craig Phillips, Sarah Joy Senior notes offering $945 million CMA CGM BNP Paribas; Citi; Deutsche Bank; Natixis; Société Générale Cravath, Swaine & Moore; Bredin Prat - Julien Gayral, Timur Celik Initial public offering $872 million Air Lease Corporation JP Morgan Securities; Credit Suisse Securities Munger, Tolles & Olson Davis Polk & Wardwell - Mary Conway, William Weigel, Kerry Price SEC-registered block trade $450 million Citadel Equity Fund (E*TRADE Financial Corporation) Morgan Stanley & Co Inc Davis Polk & Wardwell - Rachel Kleinberg, Ryan LaRosa Simpson Thacher & Bartlett SEC-registered offering $400 million ORIX Corporation Merrill Lynch, Pierce, Fenner & Smith; Morgan Stanley; UBS; Nomura; Citigroup Davis Polk & Wardwell - John Paton, Sarah Joy Simpson Thacher & Bartlett Initial public offering $384 million ING Emerging Markets High Dividend Equity Fund Morgan Stanley; Citigroup; Merrill Lynch, Pierce, Fenner & Smith; UBS; Wells Fargo; Ameriprise Dechert Davis Polk & Wardwell - Mary Conway, Kay Ng Initial public offering $106 million Sagent Pharmaceuticals Inc Morgan Stanley; Merrill Lynch, Pierce, Fenner & Smith; Jefferies & Company Kirkland & Ellis Davis Polk & Wardwell - Michael Farber, Joshua Ruland

The OECD believes the reform of property taxes, rather than any changes to corporate taxation, would help the New Zealand economy.

Taxpayers will get an opportunity to have their say on the interpretation of the term beneficial owner in the OECD Model Tax Convention.