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The draft statement of practice contains some welcome features, such as an openness to arbitration and more guidance on when invoking the mutual agreement procedure is appropriate, believe Murray Clayson and Danny Beeton of Freshfields Bruckhaus Deringer

HM Revenue & Customs (HMRC) in the UK have said they will accept the use by companies of the spread methodology, as the basis for determining the amount to include in their cost base.

Uruguay and India have signed a double tax treaty, which is being described as a milestone agreement.

The Internal Revenue Service (IRS) in the US has released proposed regulations which require select corporate taxpayers to attach a Schedule Uncertain Tax Position (UTP) statement to their income tax returns.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $7.5 billion Momentive Performance Materials Holdings Hexion Wachtell, Lipton, Rosen & Katz Deborah Paul & Tijana Dvornic Acquistion $1.5 billion Hewlett-Packard ArcSight Fenwick & West Timothy Fitzgibbon Acquistion $1.3 billion Hellman & Friedman Associated Materials Simpson Thacher & Bartlett Katharine Moir and Dan Foster Acquistion $193.5 million Boston Scientific Sunnyvale Fenwick & West Michael Solomon, Ron Schrotenboer & William Skinner Acquistion Undisclosed Battery Ventures Affiliate Special Committee of the Board of RAE Systems Fenwick & West Tim Fitzgibbon & Melinda Vance Merger Undisclosed Servo Software Synclore Fenwick & West Adam Halpern & Matthew Noerper Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Underwritten public offering $300 million City National Corporation Wachtell, Lipton, Rosen & Katz Joshua Holmes, Michele Alexander & Tijana Dvornic

Tax commissioners have said that compliance, especially in international matters, is the key to fairer tax systems and increased revenue and will facilitate a return to robust economic growth.

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Netherlands UK September 17 2010 Proposed Double Taxation Agreement Belarus Brazil

The second meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes will be held in Singapore next week.

RSM Tenon, the seventh largest accountants and business advisory firm in the UK, has made two senior appointments in its tax team.

Deloitte has expanded its tax practice in Spain with the appointment of new partners and directors, and the establishment of an office in the Balearic Islands.