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  • Gabriela Villavicencio and Armando Cabrera look how Argentina's transfer pricing rules have developed since their introduction in 1998
  • Willem Vunderink and Ronald van de Merwe, of Ernst & Young in the Netherlands
  • Dirk Van Stappen of KPMG explains some features of Belgium's new deduction for patent income
  • The three Benelux states – the Netherlands, Belgium and Luxembourg – are passionate believers in using the tax system to facilitate direct investment. They use every opportunity to refine and develop the regime to create greater economic growth.
  • Peter Dutton A draft tax bill, published by Peter Dutton, the minister for revenue, on August 16, aims to change the rules in Australia on thin capitalisation, company tax losses, capital gains tax for statutory licences, property trusts and stapled securities.
  • Eli Weiss, an attorney in the New York tax department of Frank Fried, has been elevated to the partnership. His practice focuses primarily on the representation of domestic and international clients in numerous transactions. He joined the firm in 1999.
  • Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $38.1 billion Rio Tinto Alcan Goodmans (Yi Wen Hsu) Merger Transocean ($31.7 billion) GlobalSantaFe ($17 billion) Transocean GlobalSantaFe Baker Botts Skadden, Arps, Slate, Meagher & Flom Acquisition $16.8 billion Danone Royal Numico De Brauw Blackstone Westbroek Allen & Overy Acquisition $16.3 billion Akzo Nobel ICI Slaughter and May (Jeanette Zaman, Tim Woodthorpe) Freshfields (Robert Kent, Arun Birla) Acquisition $16.2 billion Imperial Tobacco Altadis Urìa Menéndez (Rafael García Llaneza) Garrigues Acquisition $15.6 billion Continental Siemens VDO Automotive Freshfields Bruckhaus Deringer (Ulrich Blaas) Hengeler Mueller (Martin Klein) Acquisition $7.9 billion Hypo Real Estate Depfa Freshfield Bruckhaus Deringer
  • Moisés Curiel, Carlos Linares and Eduardo Méndez discuss how transfer pricing have changed since their introduction
  • America's 12th largest accountant Moss Adams has recruited Michael Ferguson as a partner in its international services group. He was formerly international tax services leader for Ernst & Young in Seattle and Portland.
  • Carl Pihlgren The Swedish ministry of finance has recently announced a proposal of changes to the CFC legislation due to the Cadbury Schweppes case (C-196/04). According to the case CFC legis-lation can be regarded as compatible with EC law if it is restricted in its application to wholly artificial arrangements. The proposal gives shareholders in lower taxed companies the possi-bility to avoid CFC taxation if certain requirements are met.