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  • Unilateral relief; Relief under the Double Taxation Relief; Taxes on Income; section 790; Income and Corporation Taxes Act 1988; ICTA 1988, Treatment of transactions in returns;
  • Only days after the UK unveiled plans to introduce a patent box, opinions are already split among the tax community as to how effective it will be.
  • The issues around the granting of treaty benefits to the income of collective investment vehicles (CIVs) are the subject of a discussion draft that the OECD Committee on Fiscal Affairs has just released
  • A member of leading think-tank in Washington, DC believes a fiscal task force would be "a stalking horse for a value added tax (VAT)" in the US
  • The approach of the Hong Kong tax authorities to source of profits issues will get stricter and more disputes with taxpayers are likely
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition £240 million ($389 million) Alberto Culver Simple Health & Beauty Group Freshfields Bruckhaus Deringer Jonathan Cooklin Acquisition Undisclosed State Street Corporation Mourant International Finance Administration Olswang Graham Chase & Ben Jones Acquisition Undisclosed Gestamp Eólica & Genera Avante Sitemas Energéticos Monfero Guitiriz Latham & Watkins Jordi Dominguez Joint Venture Undisclosed BBC Worldwide All3 Media Group Nörr Stiefenhofer Lutz Stefan Hölzemann & Kristina Schwarting Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Bond Issue $2 billion Iberdrola & Iberdrola Finance Ireland Citi, Goldman Sachs, Barclays & Bank of America Latham & Watkins Jordi Dominguez Debt Raising Transactions $1.65 billion Hanesbrands JP Morgan Securities Simpson Thacher & Bartlett Jonathan Cantor & Christian Miller
  • Type of Agreement Country Country Date Signed Link Tax Information Exchange Agreement Denmark Saint Lucia December 10 2009 Link Tax Information Exchange Agreement Sweden Anguilla December 14 2009 Link Tax Information Exchange Agreement Norway Anguilla December 14 2009 Link Tax Information Exchange Agreement Iceland Anguilla December 14 2009 Link Tax Information Exchange Agreement Greenland Anguilla December 14 2009 Link Tax Information Exchange Agreement Finland Anguilla December 14 2009 Link Tax Information Exchange Agreement Faroes Islands Anguilla December 14 2009 Link Tax Information Exchange Agreement Australia Aruba December 16 2009 Link Tax Treaty Japan Netherlands December 18 2009
  • Tax professionals have criticised the UK taxation code of practice for being "unpalatable" and "discriminatory".
  • The Dutch Ministry of Finance should be commended for introducing targeted interest deduction tax measures rather than a complete corporate tax reform package, says a leading Dutch tax professional.
  • Nikhil Mehta is stepping down as a tax partner of Cleary Gottlieb Steen & Hamilton in London. He has requalified as a barrister and will start work at Gray's Inn Tax Chambers in the new year. He became a partner of Linklaters in 1989, eventually becoming head of contentious tax. He joined Cleary Gottlieb in 2002.
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