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Redefining Successin Uncertain Times–A business perspectivefor energy executivesREUTERS/ZOHRA BENSEMRA

“ Current geopolitics, macroeconomics, supply and demandprovide opportunity, risk and reward. Over the comingdecades, the world will likely need much more energy tomeet growing demand. As before, many could be lifted outof poverty. And, as before, our industry could play a crucialrole in powering this progress.” 1 en van BeurdenBCEO, Shell at the 2017 CERAWeek, Houston, TX1 017/deliver-today-prepare-for-tomorrow.html

Redefining Business Success in Uncertain TimesTo make sense of this uncertain environment, energy companiesneed reliable, real-time information, proven technology platformsand strategic, expert partners.Energy companies are experiencingan era of unprecedented uncertainty.Climate science shows the ill-effectsof greenhouse gas emissions yetthe geopolitical environment pointstoward a resurgence of fossil fuels.The market volatility of the pastfew years has begun to reverse asthe segment expands to a moreglobal and distributed network.Simultaneously, the industry isexperiencing consolidation andcentralization, with Shared ServiceCenters playing a pivotal role inenergy-company operations.Globalization brings with itcomplexities related to internationaldistribution, regulation, taxationand litigation. Risk lurks around everycorner as diverse and distant supplychains are increasingly susceptibleto corruption and bribery.The liquefaction of gas and newtechnologies enable LNG to beconverted and transported aroundthe globe. Technology is alsofurthering the dawn of automationand robotics in the sector, whilethe changing profile of energycompanies, where consumers3are now power generators and gridsuppliers, creates a completely newdynamic as to what constitutes anenergy company.To make sense of this uncertainenvironment, energy companies needreliable, real-time information, proventechnology platforms and strategic,expert partners.Welcome to the energy era of the 21stcentury—here’s to prospering in anuncertain environment.

REUTERS/DAVID GREY

A Letter fromThomson ReutersEnergy Practice LeadEnergy is the sustenance of life. We depend on it forour 21st-century, technologically advanced existence.Whether from traditional fossil-fuel sources, moreenvironmentally friendly options, or emergingapproaches such as lithium-ion batteries or tokamakfusion, energy provides the power needed to run ourhomes, offices, vehicles, gadgets and everything elseon which we rely.Nevertheless, despite our energy dependence,the sector has faced mounting obstacles over thepast decade, making energy-company businessoperations more complex and challenging.Headlines such as “Energy drags Wall St lower”2;“TSX falls as oil slide hits energy stocks”3 and “Murkyoil inventory picture leaves market grappling forclarity”4 are some of the many that underscorethe challenging situation energy companies face.2 RYX2I3 1N1HR1U74 dUSL1N1HS1G4Economic gains and profitability once enjoyedby the sector are no longer a guarantee.Compounding the complexity of running abusiness under these market conditions are intenseregulatory pressures and an uncertain geopoliticalenvironment. Companies are challenged towork smarter. To provide (greater) shareholdervalue and returns. To increase efficiencies andproductivity while cutting costs. To embracenew technologies. Find new markets. Considerpartnerships. Essentially, to reinvent how theyoperate to ensure their longevity and profitability.Year-end 2016 results told the story of how energycompanies have been struggling. Diversificationand M&A activity provided a bit of relief for someorganizations, but not enough to turn the tide.This paper addresses the disruption corporateenergy leaders face and provides strategicinsight for optimizing tax, legal and financialoperations. We are in an ever-changing worldthat seems to grow smaller as organizationsexpand. Success in today’s environmentrequires new solutions and a new mindset.I invite you to explore our executive perspectiveon energy and reach out with any questions orsuggestions you have.With all my best for business success,Emily LyonsManaging DirectorEnergy PracticeThomson Reuters

REUTERS/LUCY NICHOLSON

Redefining Business Success in Uncertain TimesFinancial & LongevityUncertaintyIn 1789, Benjamin Franklin wrote that “In this world,nothing can be said to be certain except death and taxes.”From a business leader’s perspective, this isn’t themessage you want to convey to your Board, shareholdersor customers. Rather, you aim to give them confidenceand certainty around your organization’s growth potential,profitability, compliance, products and more.Although such assurances can be challenging, theyare nonetheless attainable with the right strategy,infrastructure and culture, even despite external factorssuch as negative environmental and social sentimentsurrounding the use of fossil fuels, overproduction of oil/crude and LNG, and the low price per barrel jeopardizingtraditionally high returns.A prime question facing c-suite executives of IOCs, NOCsand even smaller players is how to sustain growth andlongevity while adapting to constantly changing marketconditions.Diversification, mergers and acquisitions, as well as costcutting measures and operational efficiencies, are allpart of the savvy business leader’s solution for long-termbusiness success. Case in point, Total’s Chairman andCEO Patrick Poyanne said of plans to acquire a centuryold battery manufacturer: “[it] allow[s] us to complementour portfolio with electricity storage solutions, a keycomponent of the future growth of renewable energy.” 5As a leader, you need access to trusted information andinsight, reliable yet configurable technology platforms anda corporate approach that is agile, nimble and responsive.IF YOU CAN’T BUILD IT (AND EVEN IF YOU CAN), BUY ITThe Energy & Power (E&P) sector had a strong start to2017 in terms of its deals activity. From speculation of apotential mega-deal between ExxonMobil and BP valuedat 100B USD to reports of strategic partnerships betweenoil multinationals and others, it’s worth paying attention tothe key industry players and their agendas.Energy & Power (E&P) has the largest M&A investment ofall tracked by Thomson Reuters Deals Intelligence thus farthis year, with volume totaling 140.1B USD in just the firstthree months, as shown in Figure 1.5 il-majors-investments-renewable-energy-solar-wind6 Ibid7E&P numbers represent a 60 percent increase over thesame period last year, with many of the top deals beingdriven by a reorganization of corporate structures andjoint ventures aimed at increasing efficiencies andproductivity. For instance, Tulsa, Oklahoma-basedOneok’s acquisition of Oneok Partners LP for 17B USD;and, Canada’s Cenovus Energy’s purchase of FCCLPartnership, a producer of crude petroleum andnatural gas for 13.28B USD.These are on the heels of the purchase of BG by RoyalDutch Shell for 70.1B USD, which closed in 2016, andlast year’s announcement of Sunoco Logistics Partners LPintention to acquire Energy Transfer Partners LP for 51.4BUSD, as shown in Figure 2.“ The oil and gas majors are in a fascinatingplace. They’re starting to use clean-energyinvestments to hedge their bets that marketsfor oil and gas will exist decades from now.”6 Jeremy LeggettFounder, SolarCentury

Thomson ReutersFigure 1: Worldwide M&A by Sector, Q1 2017Energy and PowerMaterialsHealthcareFinancialsIndustrialsHigh TechnologyReal EstateConsumer ProductsConsumer StaplesFirst Quarter 2017 Value ( bil)TelecomFirst Quarter 2016 Value ( bil)MediaRetail0306090120150Source: Thomson Reuters Deals Market IntelligenceMOMENTUM CONTINUESMEGA DEALS ABOUNDWHAT LIES AHEADDespite the uncertain geopolitical environment, saggingprices and questions about OPEC’s production output,Thomson Reuters data shows that global deal makingactivity in the energy sector totaled 608B in 2016, anincrease of 15 percent from 2015. Last year was the largestannual period for E&P M&A since Thomson Reuters begankeeping records in 1980. Energy & Power M&A was just oneof three sectors to experience year-over-year growth during2016, driven by the largest all-time quarter increase in Q4( 253.5B USD), as shown in Figure 3. Most other industriessaw double-digit declines as the value of overall worldwideannounced M&A deals fell 16 percent during the year.Energy & Power also had 59 percent more mega deals(valued at 5B USD or more) in 2016 than 2015, with 27versus 17 such initiatives, respectively. One-quarter ofthe worldwide mega deals were from E&P, and it was theonly sector to experience increases in both the value andnumber of mega deals year-over-year, despite the overalleconomic environment.While there isn’t a crystal ball to know for certain theoutcome of an ExxonMobil/BP potential merger, or anyof the other pending energy-related deals, keeping a fingeron the pulse of M&A trends is essential for uncoveringopportunities and determining strategic partners toensure your company’s longevity. With the volatile market,ongoing low Brent and crude prices and a vacillatinggeopolitical environment, the timing appears to be rightfor the continued clip of activity seen thus far in 2017.The United States was the most acquisition-focusedcountry with 328.3B USD worth of deals, accounting for42 percent of the global M&A activity. Cross-border M&Adeals also fared quite well, accounting for 46 percent ofthe sector’s annual activity and valued at 280.3B USD.8STRATEGIES FOR SUCCESSIt’s a massive effort to track and compile M&A-relateddeals insight, and its even more complex to know howto interpret and act on that knowledge. News feedsare a source of this information, however they aretypically a rear-view-mirror look at deal making,

Redefining Business Success in Uncertain TimesFigure 2: Top Worldwide Energy & Power M&A Deals since 1980DateStatusTarget NameTarget NationAcquiror NameAcquiror NationValue ( bil)Target Mid Industry10/28/0412/01/98CompletedCompletedShell Transport & Trading CoMobil CorpUnited KingdomUnited StatesRoyal Dutch Petroleum CoExxon CorpNetherlandsUnited States95.4485.13Oil & GasOil & Gas04/08/15CompletedBG Group PLCUnited KingdomRoyal Dutch Petroleum CoNetherlands81.01Oil & ngCompletedCompletedSuez SAKinder Morgan Energy PartnersElf AquitaineAmoco CorpEnergy Transfer Partners LPTXU CorpTexaco IncFranceUnited StatesFranceUnited StatesUnited StatesUnited StatesUnited StatesGaz de France SAKinder Morgan IncTotal Fina SABritish Petroleum Co PLCSunoco Logistics Partners LPTXU Corp SPVChevron CorpFranceUnited StatesFranceUnited KingdomUnited StatesUnited StatesUnited States75.2458.5555.3452.7251.4344.3743.32PowerOil & GasOil & GasOil & GasOil & GasPowerPetrochemicalsSource: Thomson Reuters Deals Intelligenceversus an opportunistic, forward-focused one. Credibledeals intelligence data can and will give you both.When you arm your strategy and financial professionalswith access to platforms populated with reliable dealsinformation, you’ll get a first-hand view into the currentlandscape and uncover opportunities for diversificationthat could extend the life of your organization.Another consideration for increasing efficiencies andimproving your organization’s agility and nimbleness is bygiving cross-functional teams access to relevant data andanalysis platforms. For instance, legal needs to ensure it isexpediting its research and reporting to other parts of thebusiness in a risk-controlled fashion. When that happens,it increases the potential for productivity in departmentsdependent on legal information. There are different legalmanagement process solutions and even outsourcingoptions that can enable this.Figure 3: Worldwide M&A in E&P since 2007 (by quarter) 700 600Q1 ( bil)Q2 ( bil)Q3 ( bil)Q4 ( bil) 500 400 300 200 1000200720082009201020112012Source: Thomson Reuters Deals Market Intelligence92013201420152016

REUTERS/PAWEL KOPCZYNSKI

Redefining Business Success in Uncertain TimesGeopolitical UncertaintyWe’re in an era of unprecedented geopolitical uncertainty.The rise of populism has ushered in new administrations(some of which are pro-fossil-fuels); the future of OPECproduction is in question, as demonstrated in Figure 4;and regional tensions are contributing to increasedcompetition and global apprehension.Early in 2017, Rex Tillerson, the prior ExxonMobil Chairmanand CEO, was appointed as the U.S. Secretary of State.March brought U.K. Prime Minister Theresa May’s letterto the European Union officially launching the beginningof Brexit, only to have her entire Party’s future in questionfollowing the early June election. June also brought newsof U.S. President Donald Trump withdrawing from theParis Climate Accord. And, ongoing, Russian PresidentVladimir Putin and Mr. Trump play roulette. Juxtaposethis political jockeying against a geographic backdropincluding the ongoing war in the Middle East, provocativeNorth Korean actions and increasing oil production fromemerging regions, alongside reversals of regulations thatwere pro-environment and increases in crude oil shipments(Figure 5), and the clarity of uncertainty is apparent.Determining the best long-term business strategy for anindustry that typically deals in 15-to-20-year-time horizonson large projects can be a challenge, especially when theoutcome of such geopolitical maneuvers is far from certain.Even if environmental regulations are to change and thelandscape improves, the longevity of actors authoringthese actions is tenuous, making it a challenge to knowhow to proceed.Figure 4: OPEC Crude Exports (January 2016 – May 50Jan-16 Feb-16 Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16 Sep-16 Oct-16 Nov-16 Dec-16 Jan-16 Feb-17 Mar-17 Apr-17 nIraqLibyaQatarUAESource: Thomson Reuters Oil Research11VenezuelaDespite the OPEC nation’sagreement to cut productionin late 2016, the start of 2017shows fairly consistent exports,putting the OPEC-nation’scommitment to decreasingproduction in question.

Thomson ReutersFigure 5: Global Crude Oil Shipments (2015 – 2017)5048million 6Jul-16Oct-16Jan-17Source: Thomson Reuters Oil Research & Thomson Reuters EikonSUPPLIER & SUPPLY CHAIN RISKSTRATEGIES FOR BUSINESS SUCCESSIn today’s geopolitical environment and the shrinkingworld in which businesses operate, supply chains areoftentimes a source of overlooked risk.News and data feeds, such as those featuringcommodity information and trusted journalism, areessential to understanding what’s happening in today’sbusiness environment and how to respond, in real timeand with real answers.Many organizations have limited visibility into thecredibility and ethicality when looking beyond first-levelsuppliers and partners. Bribery, corruption, modern slaveryand business operations with politically exposed personscan add unnecessary reputational and financial risk toyour organization.Feeds such as those shown in Figure 6 enableorganizations to bring current-day production, flow,shipment and pricing trends in house, supplementingthem with proprietary data that makes strategic hedgingand decisions about longer-term profitability more certain.It’s essential for business leaders to have a broader viewof their supplier and supply chains in order to avoid lackof regulatory compliance and the pitfalls of dealing withcorrupt networks.“ The strategy of the U.S. Fed will influence theoil market through the effect it will have on theU.S. dollar. It is broadly expected that the Fedwill increase interest rates, resulting in an evenstronger dollar that could have an impact on oilprices and/or oil demand, although the upsidewill likely be limited. The Trump administrationis expected to create a generally favorableenvironment for U.S. oil producers, throughlower taxation and reduced environmentalregulations, that in hand can lead to a strongrecovery in the U.S. upstream oil industry.” Shakil Begg Head of Oil & Gas Research, Thomson Reuters12

Redefining Business Success in Uncertain TimesFigure 6: News & Data Feeds for Real-Time InsightThomson Reuters Data Feeds can be customized to thespecific parameters which you want to track, as well asmerged with your internal data, creating a knowledgeweb that is essential to professionals making strategicdecisions on behalf of your company.Source: Reuters News Data Feed13

REUTERS/SERGIO MORAES

Redefining Business Success in Uncertain TimesRegulatory UncertaintyAs new government regimes assume office,the regulatory atmosphere is being muddied bychanges to environmental mandates seemingly in favorof traditional energy companies 7 and a wavering ParisAccord commitment. This is happening while regulationsrelated to supply chains, knowing your customer andthird-party risk also become more stringent. Complexfinancial, legal and tax requirements are the corporatecompliance team’s raison d’etre.Figure 7: Vessel Shipment TrackingTAX REGULATIONSThe OECD’s Base Erosion and Profit Sharing (BEPS)Action Plan and its country-by-country reporting (CbCR)mandate have added to the complexity of regulatorycompliance for many energy organizations given thevolume of companies conducting business across nationalborders. Such is now the norm, as 63 percent of the world’soil is transported over maritime routes, according to theU.S. Energy Information Administration.8 Figure 7 showsrecent vessel traffic in the Persian Gulf. A view of this onewaterway depicts just how congested oceanic shipmentscan be, underscoring the complexity of country-by-countrytax reporting.Source: Thomson Reuters Interactive Map and Thomson Reuters Eikon7 -idUSKBN16Z1L68 ics.cfm?RegionTopicID WOTC15

Thomson Reuters76%Transfer Pricing201583%83%(documentation &country-by-country reporting)2016“ BEPS creates additional complexity underAction 8 for energy companies when it comes todeveloping and sharing intangibles. There is agray area between intangibles and services thatare significant to a global energy company.” Pete RobertsMarket Development Lead, Energy–Tax & Accounting,Thomson Reutersof respondents report Transfer Pricing (documentation& country-by-country reporting) as the biggestdepartmental change among all of the BEPS actions,an increase of 7 percentage points over the prior year.In a recent Thomson Reuters survey, 83 percent ofrespondents listed Transfer Pricing (documentation andcountry-by-country reporting) as the most significantchange of all BEPS Actions.9 While the concept behindtransfer pricing is clear, its manifestation can be murky,with organizations grappling to ensure they’re payingadequate taxes in jurisdictions where profits are generatedand providing accurate-and-transparent reporting. Casein point is Chevron’s legal dispute in Australia regardinglingering transfer pricing issues from 2004 – 2008.10EFFECTIVE TAX RATESTo aid in understanding jurisdictional tax requirements,the Effective Tax Rate (ETR) of an organization is used toshow the average rate at which a company pays taxesglobally. In energy, the ETR tends to be lower than thatof other industries, and significantly lower than the 35percent rate paid by many companies within the U.S.Figure 8 highlights the median ETR for various sectorsincluding energy. Energy’s ETR is 26.0 percentage, thethird lowest of all featured. This is primarily due to thelarger-than-average investment in property, plant andequipment such as oil rigs and refineries on the part ofthe IOCs.The manifestation of BEPS in combination with otherregulations and compliance mandates add to regulatorycomplexity. Energy companies must comply with currentregulations according to the rules and requirements ofeach jurisdiction. To manage this on a multinationalbasis is a detailed and time-consuming process,albeit a necessary one.9 2016/10 n-taxavoidance-idUSKBN17N08V16FINANCIAL REGULATIONSOn the financial side of the house, the Market in FinancialInstruments Directive (MiFID) II is a regulation taking effectJanuary 3, 2018 that will directly impact companies tradingenergy as a financial instrument. It fundamentally extendsthe reach of its 2007 predecessor, MiFID, which created theregulatory framework for European financial services.MiFID II will require significant changes to the operatingmodels, systems, data, personnel and processes anorganization uses. It ultimately seeks to ensure nonfinancial firms transacting commodity derivatives suchas emissions allowances are properly regulated. To makethis possible, MiFID II necessitates that various platformsformalize their status as a trading facility and publishmarket and reference data in a consistent manner.

Redefining Business Success in Uncertain TimesFigure 8: Median Effective Tax Rates by Industry (2015)SectorMedian Effective Tax RateConsumer Discretionary32.3%Consumer Staples31.9%Energy26.0%Financials27.4%Health Care25.0%Industrials31.4%Information Technology23.1%Materials27.8%Telecommunication Services33.6%Utilities34.0%AVERAGE29.3%“ MiFID II represents one of the mostfundamental and far reaching regulationsthe industry is addressing. Its effect is not justin the European Union, its ripples will reach farout into the global financial industry, impactingall financial organizations that deal with theEuropean markets.” John MasonHead of Regulatory Content Propositions,Thomson ReutersSource: Thomson Reuters I/B/E/SAccording to the Futures Industry Association (FIA.org), in order for commodities derivatives trading activities to beconsidered ancillary to a firm’s main business (which must not be a MiFID-investment business), they must constitute aminority of activities at the group level. In addition, firms must consider the size of their trading activity compared to thesize of the overall EU market’s trading activity in the particular commodity derivative. In the Consultation Paper, there aretwo threshold tests that propose firms exceeding either will be subject to MiFID II.Under the first test, where a firm’s capital employed for its eligible activities in the European Union constitutes more than5 percent of the capital employed for the overall activities of the global group, it will fall within scope of MiFID II. Eligibleactivity comprises activities listed in Article 2(1)(j) of the recast Directive. Privileged transactions (which include certainliquidity obligations, intra-group and risk-reducing transactions) will be deducted from the eligible activity. Capitalemployed for trading activity carried out by MiFID-authorized members of the group will not count toward the calculation.A group may establish a subsidiary in which all MiFID II activities requiring authorization are bundled.Under the second test, a firm will be caught by MiFID II if the size of the commodity derivatives trading activity by its groupin the European Union constitutes more than 0.5 percent of the overall market trading activity in the European Union inany of the eight specified commodity classes. These include: metals, oil and oil products, coal, emission allowances, gas,power, agricultural products, and other commodities (including freight and commodities under C10 of Annex I to therecast Directive). MiFID II will apply to firms that exceed the threshold in any of the commodity classes. Again, privilegedtransactions will be deducted from the trading activity and trading carried out by MiFID authorized members of the groupwill not count toward the calculation. There is a de minimis-proposed threshold of 0.25 percent. Entities whose commoditytrading activity falls below this level will not have to apply the first test in order to be able to invoke the ancillary exemption.It is anticipated that a number of IOCs and large multinational corporations with trading floors will be subject to theMiFID II requirements.17STRATEGIES FOR SUCCESSTransfer pricing work has traditionally been handledregionally, however many organizations are moving to acentral location, platform and process that manages allof the rules and data for the jurisdictions in which theyoperate. This allows energy corporate leaders to seecomplete transfer-pricing data in a similar format andidentifies real-time policy changes, thereby helping tolower the company’s risk.To meet the financial requirements on the horizon withMiFID II, it’s imperative that organizations work with MiFIDcompliant partners that can help them ensure their data,systems and services are compliant.

REUTERS/DAN RIEDLHUBER

Redefining Business Success in Uncertain TimesTech Disrupters andOperating UncertaintyWhether it is the expansion of renewable technologies,changing dynamics of power producers and suppliers,or corporate-operation automation, the way energycompanies run their businesses is evolving.The 21st century is a century of innovation andtechnological advancement like no other in history.Ubiquitous connectivity (the Internet of Things) coupledwith regulatory changes and environmental pressuresmake this an era that’s disrupting “business as usual,”creating new norms, identifying new competitors andforever altering the notion of what constitutes power(energy) and from where it comes.Corporate finance, legal and tax teams are being pressedto increase productivity in order to reap greater efficiencies.“Technology” is being hailed as a way to do this.Insight into the energy sector unveiled that many legaldepartments in energy companies are not yet collectingand analyzing their data in order to make data-drivendecisions . There’s an opportunity to apply a methodologyto manage external counsel, capturing matter and billinginformation in a data pool for benchmarking to trackmatters internally more efficiently and manage bills fromexternal counsel.Figure 9: Areas where in-house counsel use technology for greater efficiency (2016/2017)53% 19%Migrating electronic document storageIntegrating standard contractsEducating stakeholders on legal guidelinesImplementing document management techImplementing processes/tech to minimize riskDeveloping paperless prcess policiesImprove efficiency of collectionGreater use of paralegals internallyImplementing project management processesTracking against performance metricsRestructuring legal functionImplementing decision support technologyOutsourcing to non-law firm vendorsProject staffing with contract/temp lawyersImplementing other technologiesA recent Thomson Reuters survey of 450 legalprofessionals found that technology plays an importantrole in their future operations, as shown in Figure 9.Migrating to electronic document storage; integratingstandard contracts; and implementing documentmanagement technology are among the top five areaswhere technology is improving corporate legal departmentefficiencies.51% 11%44% 12%35% 21%34% 13%32% 15%30% 12%24% 14%TECHNOLOGY IMPACTING TAX OPERATIONS26% 11%18% 11%14% 12%14% 9%12% 8%Have or are in process of implementing13% 6%Planning for the coming year4% 4%010203040506070Source: Thomson Reuters Legal Survey198090100Technology is also impacting corporate regulations.Governments’ use of electronic tax data is makingcorporate tax management more cumbersome.Government-revenue organizations are more oftenengaging in the real-time collection, processing andreporting of tax data, proactively informing corporationswhat they owe (versus the traditional paradigm where

Thomson ReutersFigure 10A: Effective Tax Rate by Jurisdiction andHow the Corporation Comparesorganizations self-report). This makes the job of managingdirect and indirect taxes, as well as cross-bordertransactions, more difficult. And, it’s precisely why taxprofessionals need a view into global tax rates and howthey compare to jurisdictional norms, such as is shown inFigures 10A and 10B.STRATEGIES FOR BUSINESS SUCCESSPre-configured, end-to-end technology solutions areincreasingly more important for improving corporatebusiness operations and compliance. Workflow platformsthat enable users to manage the full extent of their supplychains, multi-jurisdictional tax filings and global vesselshipments (among other data points) are essential tomaintaining efficiencies and increasing productivity.Another technological mainstay that’s providingtangible benefit to energy CTOs is the transition tocloud-based storage solutions. The move from manualdata management via large Shared Service Center teamsto a hosted environment utilizing the cloud can freeup large numbers of staff for other tasks, resulting inincreased productivity and operational efficiency, whiledecreasing certain overhead expenses.Source: Thomson Reuters ONESOURCE BEPS Action Manager“ With the legal market and energy sector bothexperiencing significant change, it could be said thatlegal departments supporting energy corporationsface the perfect storm.Figure 10B: Tax Rate Comparisons Legal functions focused on delivering value are makingdata driven decisions regarding engagements withexternal counsel, utilizing technology to speed upinternal processes, exploring ways to offer self servicesolutions and seeking the right mix of in house,alternative legal service provider and externalcounsel support for their matters.”Source: Thomson Reuters ONESOURCE BEPS Action Manager Christopher JefferyMarket Development Lead, Legal20

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11/21/16 Pending Energy Transfer Partners LP United States Sunoco Logistics Partners LP United States 51.43 Oil & Gas 02/26/07 Completed TXU Corp United States TXU Corp SPV United States 44.37 Power 10/16/00 Completed Texaco Inc United States Chevron Corp United States 43.32 Petrochemicals Figure 2: Top Worldwide