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Danny Beeton, Murray Clayson and Helen Gilbey of Freshfields Bruckhaus Deringer in London outline key features of IP-related transfer pricing legislation, disputes and practice in the UK and forecast that the tax authorities will only get more aggressive about intangible assets.

The treatment of intangibles is one of the most hotly debated topics in transfer pricing today.

Deutsche Bank will pay the US government more than half a billion dollars to settle an action over its role in “tax-oriented transactions”.

Oliver Wehnert of Ernst & Young says taxpayers in Germany must have robust policies concerning transfer pricing of intangibles if they do not want to suffer adjustments and risk double taxation

Hendrik Fügemann, Philip de Homont and Alexander Voegele of NERA in Frankfurt discuss a brand valuation case study involving a European parent and Latin American subsidiaries

Multinational taxpayers can avoid risk in IP transactions in Russia if they are vetted in advance for their legal, tax and even customs implications, believe Fedor Blinov, Alexey Korabelnikov and Igor Nevzorov of Ernst & Young

India’s tax authorities should issue some guidance to deal with the transfer pricing of marketing intangibles, believe Rohan Phatarphekar and A Pradeep of KPMG

Developing transfer pricing policies for IP migration requires a patient, diligent and thorough approach, believe Keith Reams, Mark Nehoray and Emily Dickert of Deloitte

The California Court of Appeal held that a state law which subjects taxpayers to a penalty for a tax understatement in excess of $1 million is constitutional.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.1 billion Thermo Fisher Scientific Dionex Wachtell, Lipton, Rosen & Katz - Joshua Holmes Cooley - Susan Philpot Acquisition Undisclosed Tailwind Capital Apex Davis Polk & Wardwell - Kathleen Ferrell and Gregory Hannibal Acquisition Undisclosed Tishman Speyer Cap de Seine complex De Pardieu Brocas Maffei - Alexandre Blestel Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Reserved share capital increase $1.2 billion Areva Agence des Participations de l'Etat ($400 million) and Kuwait Investment Authority ($800 million) Gide Loyrette Nouel Bredin Prat for French State - Patrick Dziewolski & Barthélémy Courteault. Gibson, Dunn & Crutcher for KIA Public Offering $1 billion IBM Barclays; UBS Davis Polk - Michael Mollerus