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  • When Dave Hartnett, HMRC's permanent secretary for tax, told the Tax Planning Strategies meeting in Paris, organised by the IBA, the ABA, IFA and the OECD, that the UK is to lead a survey into the practicality of global transfer pricing guidelines, you could be sure that practitioners around the world would have an opinion.
  • Advance pricing agreements (APAs) in the US continue to grow in popularity, statistics indicate.
  • Watson Farley & Williams has announced the promotion of both Romain Girtanner and Verena Scheibe to the position of tax partner.
  • Environmentalists have welcomed the European Commission’s proposals to revise the Energy Taxation Directive (ETD), but green groups do not believe it goes far enough, fast enough.
  • If Northern Foods had merged with Greencore, it would have been the first merger involving a UK company structured under the EU Cross-Border Mergers Directive (ECBMD). Salman Shaheen talks to one of the architects of the deal to see what new tax challenges this threw up.
  • Sibel Owji has been appointed to the position of partner in DLA Piper’s International Tax Group. She is based in the firm’s San Francisco office.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.1 billion Silgan Holdings Inc Graham Packaging Company Inc JP Morgan; Davis Polk & Wardwell Acquisition $446 million ContourGlobal Gas Natural (Arrubal La Rioja) Uría Menéndez - Guillermo Canalejo Clifford Chance - Barcelona office Acquisition financing $335 million The Priory Group Craegmoor Group Limited Shearman & Sterling - Iain Scoon, Bernie Pistillo, Shiu-Kay Hung, James Leslie Acquisition Undisclosed EDF EDF Energies Nouvelles Davis Polk & Wardwell Linklaters Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) SEC-registered common stock offering $335 million Catalyst Health Solutions Goldman, Sachs & Co; Citigroup Global Markets Inc Latham & Watkins Davis Polk & Wardwell - Neil Barr, Patrick Sigmon, Lauren Murphey Debt tender offers $277.6 million El Paso Corporation RBC Capital Markets, Societe Generale Davis Polk & Wardwell - Po Sit, Niya Tang SEC-registered offering $250 million Hormel Foods Corporation JP Morgan Securities; Merrill Lynch, Pierce, Fenner & Smith Davis Polk & Wardwell - Michael Farber, Catherine Tennant
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Singapore Spain April 13 2011
  • Pallavi Joshi Bakhru of Walker, Chandiok & Co dissects the 2011 union budget and discovers that the government has made a number of significant changes that should prepare taxpayers for the introduction of the Direct Taxes Code next year.
  • The 2011 Finance Bill included a number of transfer pricing provisions including widening the powers of transfer pricing officers. Rajendra Nayak of Ernst & Young explains that these changes, twinned with a number of recent disputes means that taxpayers should begin preparing for more audits and disputes.