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  • Foster's Brewing Group has said it received a favourable judgment from the Full Federal Court of Australia on April 8 in a dispute with the tax authorities over a tax assessment relating to the funding of its Elders Finance Group in the 1980s and 1990s.
  • The Department of Finance in Dublin said it is unlikely to adopt the recommendations of a group of six Irish charities to adapt the transfer pricing regime.
  • A new tax law is effective in Qatar with specific transfer pricing implications, including advance rulings.
  • Media company, Bloomberg, will not appeal a Russian court decision that said its Russian operations constituted a permanent establishment (PE).
  • Senior Principal, Steve Harris, based in New York, will lead a new Global Transfer Pricing Services India (GTPS) initiative. Harris will work with Rohan Phatarphekar (GTPS leader – India) and the KPMG India team on behalf of all KPMG member firms.
  • The number of field audits may be increasing globally, but the auditors’ approach in each jurisdiction is not the same.
  • Companies may get an incentive to look at the UK more favourably when making investment decisions if reports in the media are to be believed.
  • With more economic activity comes more pressure on tax directors to be certain that the processes, systems and structures they have in place will help them achieve tax-efficient outcomes.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.9 billion Solvay Rhodia Freshfields, Bruckhaus & Deringer; Gide Loyrette Nouel - Laurent Modave; Loyens & Loeff - Christophe Laurent Bredin Prat - Julien Gayral, Jean-Florent Mandelbaum Merger $2.35 billion Diamond Foods Pringles (Procter & Gamble) Fenwick & West - Michael Solomon, Will Skinner Acquisition $500 million Safran SNPE Matériaux Energétiques Gide Loyrette Nouel - Guillaume Jolly, Marina Rodrigues Bredin Prat - Pierre-Henri Durand, Magali Buchert Acquisition $169 million Watts Water Technologies Danfoss Socla Bredin Prat - Julien Gayral Acquisition $60.75 million Swiss Liberty Sdn Bhd (TA Global Bhd) Swissôtel Kunshan (Kingdom Hotel Investments) Blake Dawson Hogan Lovells - Philip Gershuny Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Acquisition financing $2.05 billion Diamond Foods Bank of America; Merrill Lynch, Pierce, Fenner & Smith Fenwick & West Davis Polk & Wardwell - Avishai Shachar, Michael Bretholz Secondary offering $1.2 billion Repsol YPF Credit Suisse; Deutsche Bank; Goldman Sachs; Itau BBA; Morgan Stanley; Raymond James; Santander Investment Davis Polk & Wardwell - Mary Conway, Rachel Kleinberg, Rhiannon Nakano Simpson Thacher & Bartlett SEC-registered secondary offering $1 billion NXP Semiconductors NV Credit Suisse Securities; Goldman Sachs & Co; Morgan Stanley & Co Simpson Thacher & Bartlett Davis Polk & Wardwell - John Paton, Adam Perry SEC-registered offering $450 million Verisk Analytics Merrill Lynch, Pierce, Fenner & Smith; JP Morgan Securities Davis Polk & Wardwell - Harry Ballan, Juelle Gomes Skadden, Arps, Slate, Meagher & Flom Term loan credit facility $325 million Western Refining Bank of America Davis Polk & Wardwell - Catherine Paskoff Chang, Juelle Gomes Shearman & Sterling
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Macedonia Kosovo April 6 2011 Tax Information Exchange Agreement Isle of Man Mexico April 11 2011