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Since the economic substance doctrine was codified, or written formally into US law, in the Health Care and Education Affordability Reconciliation Act of 2010, tax professionals have been wary of its effect on the ability of taxpayers to lawfully enter into certain transactions.

The US Tax Court has revisited a decade-old law on interest-netting and has ruled in the taxpayer’s favour.

The Brazilian Ministry of Revenue (BMR) is helping exporters by tweaking its approach to transfer pricing again.

Li Ying, transfer pricing director at Siemens China, talks to Sophie Ashley about her personal experience with cost sharing, dealing with the authorities and why China’s attitude to copyright is stopping companies from transferring their IP to the country.

A UK economist has told TPWeek that UK taxpayers do not want lawyers and accountants to approach them with tax planning arrangements because the risk of being exposed by the media is too great.

Singapore tax professionals got what they wished for as the annual budget delivered incentives and R&D initiatives to boost the country’s competitiveness in the region.

The European Commission is launching a public consultation today on the taxation of the financial sector.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4 billion West Australian Newspapers Holdings Ltd Kohlberg Kravis Roberts & Co (Seven Media Group) Allens Arthur Robinson; Freehills Baker & McKenzie - Tim Sherman Acquisition $2.6 billion Clariant International Ltd Süd-Chemie AG White & Case - Josef Honebrink Skadden, Arps, Slate, Meagher & Flom; Hengeler Mueller; Baer & Karrer Acquisition $900 million Jacobs Engineering Group Inc Aker Solutions ASA Paul, Hastings, Janofsky & Walker - Alexander Lee, Arun Birla Acquisition $270 million Kratos Defense & Security Solutions Inc Herley Industries Inc Paul, Hastings, Janofsky & Walker - Alexander Lee Jefferies & Company; Credit Suisse Securities Acquisition $127 million Equinix Inc ALOG Data Centers do Brazil Davis Polk & Wardwell - Rachel Kleinberg, Ryan LaRosa Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Bond offering $840 million Towergate Finance plc Advent International Corporation Shearman & Sterling - Iain Scoon, Simon Letherman, James Leslie IPO $107 million Gevo Inc Khosla Ventures; Virgin Green Fund Paul, Hastings, Janofsky & Walker - Alexander Lee

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Malaysia Qatar February 17 2011 Double Taxation Avoidance Agreement Germany Cyprus February 21 2011

The Australian Board of Taxation has set up a consultation about how to make progress on proposals to redesign the tax system with the publication of the Post-implementation Review of the Tax Design Review Panel Recommendations discussion paper.