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Young Gee Park

Christof Letzgus In National Grid Indus the European Court of Justice (ECJ) recognised the right of an EU member state to assess capital gains taxes on unrealised gains of a corporation resident in the Netherlands which transferred its place of management to the UK. This restriction of the corporation's freedom of establishment had to be proportionate, though, which could limit the right of the member state to immediately collect the tax assessed. In the recent DMC decision, the ECJ took the opportunity to comment on the German exit taxation rules.

Sabrina Wong

Ayesha Lau

Rajendra Nayak

Giuliano Foglia

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Proposal To Acquire $6.8 billion Tyson Foods Inc. The Hillshire Brands Company Davis Polk & Wardell LLP - Neil Barr Acquisition $370 million Mitsubishi UFJ Lease & Finance Company Engine Lease Finance and Beacon Intermodal Leasing Davis Polk & Wardell LLP - Kathleen Ferrell Mori Hamada & Matsumoto and Milbank, Tweed Hadley & McCloy LLP Acquisition $260 million Shire plc Lumena Pharmaceuticals Inc. Davis Polk & Wardell LLP Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $2.5 billion Celgene Corporation Merrill Lynch, Pierce, Fenner & Smith Inc., Credit Suisse Securities LLC, Goldman Sachs & Co., Morgan Stanley & Co. LLC Poskauer Rose LLP Davis Polk & Wardell LLP - Neil Barr Public Offering $2 billion JD.com Merrill Lynch, Pierce, Fenner & Smith Inc., UBS Securities LLC Skadden, Arps, Slate, Meagher & FlomLLP, Zhong Lun Law Firm, Maples and Calder Davis Polk &Wardell LLP - John Paton, Rhiannon Nakano Notes Offering $2 billion Caterpiller Barclays Capital Inc., J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Inc. Sidley Austin LLP Davis Polk & Wardell LLP - Michael Mollerus, Ameya Lae Convertible Notes Offering $1.3 billion Cobalt International Energy Inc. Goldman Sachs & Co., RBC Capital Markets LLC Shearman & Sterling LLP Davis Polk & Wardell LLP - Lucy Farr, Michael Mollerus, Vinay Prabhakar Senior Notes Offering $500 million Mead Johnson Nutrition Company Citigroup Global Markets Inc., Goldman Sachs & Co., J.P. Morgan Securities LLC, Morgan Stanley & Co. LLC Mayer Brown LLP Davis Polk & Wardell LLP - Harry Ballan, Gregory Hannibal Notes Offering $500 million Eastman Chemical Company J.P. Morgan Securities LLC, Merrill Lynch, Pierce, Fenner & Smith Inc., Wells Fargo Securities LLC Jones Day Davis Polk & Wardell LLP - Kathleen Ferrell, Sam Van Peperstraete Acquisition Financing $485 million Shearer's Foods Credit Suisse Securities LLC, Deutsche Bank Securities Kirkland & Ellis LLP Davis Polk & Wardell LLP Credit Enhanced Bonds Offering $136 million Rizhao Port (Hong Kong) Company Ltd. ABCI Capital Ltd., Barclays Bank PLC DLA Piper, DHH Law Firm Davis Polk & Wardell LLP - Alon Gurfinkel, Dominic Foulkes Senior Notes Offering $50 million Scorpio Tankers Inc. Stifel, Nicolaus & Company, Incorporated, Deutsche Bank Securities Inc., Jerfferies LLC Seward & Kissel LLP Davis Polk & Wardell LLP - Harry Ballan, William Curran

Samantha Merle Having agreed on its content by the end of February, Luxembourg and the US signed an intergovernmental agreement (IGA) implementing the Foreign Account Tax Compliance Act (FATCA) on March 28. Luxembourg and the US negotiated a Model 1 IGA, requiring the Luxembourg tax authorities and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US citizens and by persons resident in the US in financial institutions resident in Luxembourg. The IGA is reciprocal, which means the US will also have to report account information about Luxembourg individuals and entities in the US to the Luxembourg tax authorities. The IGA will enter into force either on the date of Luxembourg's written notification to the US that Luxembourg has completed its necessary internal procedures for the entry into force of the IGA, or on the date of the US written notification to Luxembourg that its applicable procedures for ratification of the amending protocol to the 1996 income tax treaty, signed on May 20 2009, have been satisfied, whichever date comes last.

Elena Kostovska A decision defining the categories of supply of goods and services for which the VAT responsible taxpayer is considered to be the entity to which the supply is being provided by another VAT-registered company was published in the Official Gazette 45/2014 and is applicable as of March 5 2014. The decision lists goods and services on which a reverse charge VAT mechanism is applied as of the aforementioned date and onwards. It also defines the appropriate steps that the involved parties need to follow in such transactions. Namely, the provider of the affected goods/services must indicate that "the VAT liability is transferred to the recipient of the goods/services according to Article 32, point 1 of the VAT Law" on the invoices issued. The provider will neither calculate VAT on the outgoing invoice, nor consider such outgoing VAT in their VAT return. The recipient of the goods/service, on the other hand, will now be obliged to calculate and pay the VAT to the Tax Office while also using their right for deduction of such input VAT.

Donald Vella