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Carl Pihlgren Sara Bolmstrand In January 2007 the Swedish Tax Agency published a new statement as regards interest deductions. The Tax Agency claimed that the Swedish Tax Evasion Act should be applicable in internal reorganisations that included a debt push down into a Swedish company, having the effect that the interest on such a loan should not be deductible. The Tax Agency's argument was that no other business reason existed to support the transaction, except for achieving a tax advantage. In addition, the Agency argued that since no need for financing existed the interest payments should therefore be classified as group contributions which are not deductible, if paid to a recipient abroad not having a permanent establishment in Sweden. In the statement the Tax Agency explicitly stated that it would not challenge debt introduced in relation to third party acquisitions. It should also be noted that the example mentioned by the Tax Agency regarded a payment of interest to a tax haven company.

Edward Tanenbaum Diana Wessells On December 24 2007, the IRS published guidance on what is commonly referred to as the anti-stuffing rule under the section 367(a) Treasury regulations (see chief counsel advice 200751024). The IRS has provided little in terms of substantive guidance on the anti-stuffing rule since its effective date more than 10 years ago. The chief counsel advice now provides some helpful content to the rule, but also raises some uncertainties.

Svetlana Stroykova Ilarion Lemetyuynen In the March 2007 issue of International Tax Review we wrote that new Russian transfer pricing rules were expected to be enacted in the near future and described the key provisions of the draft transfer pricing law developed by the Russian Ministry of Finance.

Luis Viñuales The bubble of the Spanish real estate market seems to have burst and real estate companies may need to look to business reorganisations and joint ventures. The merger of two real estate companies raises some particular tax issues that have been addressed in decisions of the Central Economic-Administrative Tribunal (TEAC) of March 2 and May 4 2007.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $3.4 billion Roche Holding Ventana Medical Systems Davis Polk & Wardwell, Michael Mollerus & David Morris Sidley Austin, Sharp Sorenson Acquisition $1.5 billion AXA ING Seguros Debevoise & Plimpton, David Schnabel & Rafael Kariyev Cleary Gottlieb Steen & Hamilton, Kristofer Hess Acquisition $1.1 billion Kazakhmys Ekibastuz coal-fired power plant and the Maikuben West coal mine in Kazakhstan Allen & Overy Acquisition $1.05 billion Tata Chemicals General Chemical Industrial Products Hogan & Hartson, Scott Friedman Acquisition ?600 million ($890 million) La Caixa Spanish private banking business of Morgan Stanley Freshfields Bruckhaus Deringer Uría Menéndez, Rafael García Llaneza Acquisition £363 million ($707 million) GE Healthcare Life Sciences Whatman Slaughter and May, Gareth Miles & Ruth Evans Acquisition ?290 million ($422.5 million) Indian Sona Okegawa Precision Forgings ThyssenKrupp Präzisionsschmiede & ThyssenKrupp Precision Forge Shearman & Sterling, Johannes Frey Hengeler Mueller, Martin Klein Acquisition $395 million 3i Active Pharmaceutical Ingredients Linklaters, Lars Jonsson, Lina Hansson, Odile Fallenius, Stephen Land, Francisco Duque, Andrew Bloom Cravath Swaine & Moore, Stephen Gordon & Christian Brause Acquisition £174.5 million ($340 million) 3i Ultralase Travers Smith, Simon Skinner Garrigues Carlos Peiro & Javier Calatayud & Taylor Wessing, Nikol Davies Acquisition £145 million ($284 million) Cinven Limited LGV Capital Partners (Classic Hospitals Group ) Freshfields Bruckhaus Deringer Ashurst, Tom Cartwright Merger $200 million Kimco Realty Corporation Valad Property Group Wachtell, Lipton, Rosen & Katz, David Einhorn & Joshua Holmes Acquisition £58 million ($115.4 million) Tangerine Confectionery Monkhill (owned by Cadbury Schweppes) Dickson Minto Slaughter and May, Sara Luder & Ruth Evans Acquisition $105 million Diageo Rosenblum Cellars Sullivan & Cromwell, Ronald Creamer, Davis Wang & Janna Freed Acquisition $103 million Aastra Technologies Ericsson's enterprise communications business McCarthy Tétrault Acquisition ?41.5 million ($61.6 million) Movie Associations, subsidiary of Entertainment One RCV Entertainment Mayer Brown, Sandy Bhogal Acquisition £21.8 million ($42.8 million) Thomas Cook Group hotels4u.com Slaughter and May, Graham Airs, Sara Luder & John Meehan Maclay, Murray & Spens Acquisition $38 million 20-20 Technologies Planit Fusion Osborne Clarke, Ronan Lowney Acquisition £12.5 million ($24.9 million) Speedy Hire AMEC Pinsent Masons, John Christian Berwin Leighton Paisner, Neal Todd & Joanne Lifton Acquisition $6 million Metalrax Group Post Glover LifeLink Frost Brown Todd, Deloitte & Touche Acquisition £2.4 million ($4.8 million) Excel Maritime Carriers Quintana Maritime White & Case, William Dantzler & Michael Masri Morgan, Lewis & Bockius Acquisition Undisclosed AOL Goowy Media Simpson Thacher & Bartlett, Marcy Geller & Jonathan Goldstein Acquisition Undisclosed Stantec Secor International (owned by Arlington Capital Partners) Shearman & Sterling, Laurence Crouch, Eileen O'Pray, Anthony Eppert, Anil Kalia Gibson Dunn, Art Pasternak & Benjamin Rippeon Acquisition Undisclosed Sumitomo Heavy Industries Demag Ergotech Nörr Stiefenhofer Lutz, Tim Dümichen Hengeler Mueller, Martin Klein Acquisition Undisclosed Atempo Lighthouse Global Technologies Fenwick & West, Ron Schrotenboer Crowell & Moring, Charles Hwang & Jennifer Ray Acquisition Undisclosed Merrill Lynch Global Private Equity LGV Capital Partners (IDH Group) Clifford Chance CMS Cameron McKenna, Steven Sieff Acquisition Undisclosed Atisreal UK Hill Woolhouse Travers Smith, Simon Yates Gordons Acquisition Undisclosed OK Hockey NHL's Tampa Bay Lightning Weil Gotshal & Manges, Jared Rusman In-house counsel Acquisition Undisclosed Assa Abloy SimonsVoss Technologies Freshfields Bruckhaus Deringer, Norbert Schneider & Ernesto Drews Shearman & Sterling, Thomas Fox & Andreas Scheidle Acquisition Undisclosed Cognetas Fink Holding SJ Berwin, Markus Hill, Carsten Ludwig Acquisition Undisclosed Sun Microsystems Innotek Gleiss Lutz, Achim Dannecker & Alexander Werder Reichert & App Rechtsanwalte Steuerberater, Juergen Reichert Type of Deal Value Issuer/borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) IPO $1.1 billion MPX Energia UBS Securities Davis Polk & Wardwell, William Weigel & Joshua Ruland White & Case, Ray Simon Listing $130 million ReneSola Credit Suisse & Deutsche Bank Securities Pinsent Masons, Liz Morgan Bond offering Ps 1.2 billion ($111 million) The Export-Import Bank of Korea Merrill Lynch International Davis Polk & Wardwell, John Paton & Nora Newton Muller

Bruno Gasparotto, VAT principal of Arendt & Medernach, says that recent European Court of Justice cases have muddied the water on the VAT recovery principles of holding companies

Nélio Weiss Philippe Jeffrey For a third consecutive year and with the objective to minimise the effect for Brazilian exporting companies from the appreciation of the local currency in relation to foreign currencies (more specifically the US dollar and the Euro), the Brazilian authorities issued on December 28 2007, ordinance 329 and normative instruction 801 which amended the Brazilian transfer pricing legislation. As per the ordinance and normative instruction, Brazilian exporting companies will be allowed to increase their export revenues for calendar year 2007 (for transfer pricing calculation purposes) using the ratio of 1.28. This measure will apply for the fiscal year 2007. As mentioned, a similar measure was also adopted for fiscal years 2005 and 2006, allowing the Brazilian exporting companies to increase their export revenues using then a ratio of 1.35 and 1.29 respectively.

February was characterised – if by nothing else – by a surge of proposals to cut corporate taxes. Across the world governments announced that they would deliver proposals to national parliaments to make significant cuts to the headline corporate tax rates in their countries. Some of these were simple and fairly straightforward packages; others were vastly more complicated including sliding scales and lower rates for small businesses. But, in essence, each of these jurisdictions felt the pressure of international competition tightening.

Blake, Cassels & Graydon has promoted John Leopardi, Paul Stepak and Kevin Zimka to the firm's partnership.

Conor Hynes of Deloitte explains why Ireland will keep its appeal for international finance