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Failure of a member to fulfil obligations – Directive 69/335/EEC – Indirect taxes on the raising of capital – Capital duty – Exhaustive harmonisation – National legislation providing for taxation of any transfer of the effective centre of management or registered office, in so far as the company concerned is not subject to capital duty in the member state of origin – National legislation under which agricultural cooperative organisations, and associations or consortia thereof of any kind, are exempted from the tax – National legislation under which co-ownership of vessels, shipping consortia and any form of shipping company are exempted from the tax – Prevention of tax avoidance – Abuse of rights – Limitation of the temporal effects of a judgment.

Free movement of capital – Corporation tax – Payment of dividends – Exemption for dividends paid to resident companies – Withholding tax levied on dividends paid to non-resident companies – Double taxation convention – Possibility of setting off the amount withheld against tax due in another member state.

Europe's leading international tax advisers and their clients gathered at the Dorchester Hotel in London on May 25 for International Tax Review's third annual European Tax Awards

Bob van der Made On May 7 2007, the Commission announced that it has opened infringement proceedings against the Czech Republic, Denmark, Lithuania, the Netherlands, Poland, Portugal, Slovenia, Spain and Sweden for their discriminatory taxation of dividend and interest payments to foreign EU pension funds. These 9 member states have been issued with letters of formal notice, the first of the three stages of the EU infringement procedure under Article 226 of the EC Treaty, the state must reply to the Commission within two months after receipt of the formal notice.

Pepper Hamilton in New York has announced that Steven Bortnick, a lawyer concentrating on domestic and international tax and private equity matters, has joined the firm as a partner. He will divide his time between the firm's New York and Princeton offices.

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Joint venture £142.5 million ($280.9 million) Land Securities (UK) Countryside Properties (UK) Slaughter and May (William Watson, Simon Letherman, UK) Campbell Hooper (Jane Innes) Joint venture £120 million ($237 million) Constellation Brands (US) Punch Taverns (UK) Ashurst (Richard Palmer, Tom Cartwright, UK) Slaughter and May (UK) Acquisition $1.54 billion Basic Element (Russian Machines) (Russia) Magna International (Canada) Cravath, Swaine & Moore (Stephen Gordon, Christian Brause, US), Bennett Jones (Canada), Egorov Puginsky Afanasiev & Partners (Russian) Osler, Hoskin & Harcourt (Firoz Ahmed, Monica Biringer, Canada) Acquisition $7.4 billion Cerberus Capital Management (US) Chrysler (US) Schulte Roth & Zabel (US) Shearman & Sterling (Peter Blessing), US Acquisition Undisclosed AWAS (Ireland) Pegasus Aviation Finance Company (US) KPMG (Paul Cooper, Melissa Geiger, UK; Jim Sams, US; Brian Daly, Tom Woods, Ireland) Deloitte & Touche Exchange n/a Travel Media (previously owned by Discovery Communications (US)) 25% of Discovery Communications (previously owned by Cox Communications (US)) Debevoise & Plimpton (Peter Furci, Matthew O'Halloran, US) Dow Lohnes (Joyce Gwadz and James Saxenian, US) Acquisition €4.9 billion ($6.7 billion) Mylan Laboratories (US) Generic drug operations of Merck (US) Cravath, Swaine & Moore (Christian Brause, US), Freshfields Bruckhaus Deringer (Germany) Skadden (US) Acquisition €255 million ($344 million) Odewald & Compagnie (Germany) IWKA (Germany) Heuking Kühn Lüer Wojtek (Germany), Ashurst (Nina Siewert, Germany) Hengeler Müller (Germany) Acquisition €260 million ($351 million) Northgate Information Solutions (UK) Arinso International (Belgium) KPMG (Russell Hampshire, Sharon Baynham, UK; Luc Heynderickx, Belgium) KPMG (Paul Op De Beeck, Belgium) Acquisition Undisclosed Hikma Pharmaceuticals (Jordan) Thymoorgan (Germany) Ashurst (Klaus Herkenroth, Nina Siewert, Germany) Sozietät Kopp Müller Kopp Sieland (Germany) Acquisition $2.7 billion Liberty Mutual (US) Ohio Casualty (US) Debevoise & Plimpton (Peter Furci, Jennifer Whetsell, US) Sullivan & Cromwell (US) Acquisition $22 billion Dolan Family Group (US) Cablevision Systems (US) Debevoise & Plimpton (Peter Furci, Bruce Haims, Rhea Gordon, William Mulvey, Charles Wachsstock, US) Sullivan & Cromwell (US) Acquisition £11.1 billion ($21.9 billion) KKR (US) / AB Acquisitions Alliance Boots (UK) Clifford Chance (UK) Simpson Thacher & Bartlett (US) Slaughter and May (UK) Merger about £100 million ($197 million) Rutland Trust (UK) August Equity Trust (UK) Slaughter and May (Tony Beare, Philip Higham, UK) Herbert Smith (UK) Acquisition $950 million Pearson (UK) Harcourt Assesment (US) and Harcourt Education International (UK) Freshfields Bruckhaus Deringer (Jenny Doak, UK) Acquisition £420 million ($827.9 milllion) Ontario Teachers' Pension Plan Board (Canada), Victorian Funds Management Corporation (Australia) 48.25% stake in Birmingham Airport (UK) Ashurst (Nicholas Gardner, UK) Linklaters (UK) Type of deal Value Issuer/Borrower Lead managers/ arrangers Adviser to issuer/borrower (tax) Adviser to lead manager(tax) Notes issue €300 million ($405 million) PULS CDO 2007-1 (Germany, Austria, Switzerland) Merrill Lynch (US), Advisium (the Netherlands), Capital Securities (US) Matheson Ormsby Prentice (Ireland) Ashurst (Nina Siewert, Nicole Benzler, Germany), Freshfields Bruckhaus Deringer (UK, Germany), Bär & Karrer (Switzerland), Binder Grösswang (Austria) Proposed placing and listing more than £400 million ($790 million) 3i (UK) ABN Amro Rothschild (the Netherlands/ UK) Slaughter and May (Graham Earles, Parita Hemmati, Philip Higham, UK) Freshfields Bruckhaus Deringer (Rob Kent, UK) Placing £750 million ($1.48 billion) BAE Systems (UK) Hoare Govett (UK) Slaughter and May (Gareth Miles, Timothy Woodthorpe, UK) Freshfields Bruckhaus Deringer (Jonathan Cooklin, Eli Hillman, UK)

Gerard Cops and Kurt De Haen, PricewaterhouseCoopers in Belgium, outline a new concession for patent development

By looking beyond traditional definitions of rent, Claire Jones finds out that it is more than just property companies that can profit from the UK's Reit regime