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  • Lowering taxes to attract investment is not just the preserve of nations. Regional rivalries within federal states can cut an international taxpayer's costs. But as Claire Jones and Catherine Snowdon found out, different regional regimes can also make life a lot trickier
  • Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition £479 million ($930 million) David Richards (UK), John Sinders (US), Investment Dar Company and Adeem Investment Company (Kuwait) Aston Martin (UK) Clifford Chance (UK) Skadden (Tim Sanders, Charlotte Fallon, UK) Acquisition $311.5 million Investcorp (Bahrain) Moody International (US) PricewaterhouseCoopers KPMG (Tom McGinness, Mark Cowland, Laura Keer, UK) Acquisition $275 million Star Capital Partners (UK) General Electric Commercial Aviation Training (US) Norton Rose Weil Gotshal & Manges (Jane Scobie, UK) Acquisition $135 million Cisco Systems (US) Reactivity (US) Fenwick & West (Ron Schrotenboer, US) Merger $100 million BZ Acquisition Corp/ Steel Partners II (US) Bairnco (US) Olshan Grundman Frome Rosenzweig & Wolosky (US) Debevoise & Plimpton (Gary Friedman, US) Acquisition £297 million ($577 million) Impala Platinum (South Africa) African Platinum (South Africa) Bell Dewar (South Africa) Linklaters (UK) Simmons & Simmons (Nick Cronkshaw, Darren Oswick, UK) Acquisition KD 1.1 billion ($3.8 billion) Qtel (Qatar) Wataniya Telecom (Kuwait) Trowers & Hamlins (Bahrain) Weil Gotshal & Manges (UK) Acquisition £1.01 billion ($1.96 billion) Apollo Management (US) Countrywide (UK) Slaughter and May (UK) Ashurst (Alexander Cox, UK) Acquisition $9.6 billion BBVA (Spain) Compass Bancshares (Spain) Cleary Gottlieb Steen & Hamilton, Garrigues (Spain) Uría Menéndez (Rafael Vargas, Rafael Fuster, Spain) Acquisition attempt £715 million ($1.39 billion) Castle Bidco (UK) Crest Nicholson (UK) DLA Piper Linklaters Acquisition $3.2 billion Cisco Systems (US) WebEx (US) Fenwick & West (Ron Schrotenboer) Pillsbury Winthrop Shaw Pittman (US) Acquisition undisclosed Microsoft (US) TellMe (US) K&L Gates (US) Fenwick & West (Ron Schrotenboer, Tim Fitzgibbon, US) Type of deal Value Issuer/Borrower Lead managers/ lenders Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Debt placing $800 million Shire (UK) Morgan Stanley (US), Goldman Sachs (US), Deutsche Bank (Germany) Slaughter and May (UK), Davis Polk & Wardwell (US) Fund closing $12 billion Providence Equity Partners (US) n/a Debevoise & Plimpton (Adele Karig, Rafael Kariyev, US) n/a Financing agreement €500 million ($666 million) Renta Corporación (Spain) SCH (Spain), Eurohypo (Germany), Fortis Bank (Belgium) Uría Menéndez DLA Piper Bond issue $2.53 billion Aldar Properties (Jersey) Barclays Capital (UK), Credit Suisse (Switzerland), National Bank of Abu Dhabi (UAE) Clifford Chance (UAE and UK)/Simmons and Simmons (UAE) Denton Wilde Sapte (UAE and UK) Placing £570 million ($1.11 billion) Mecom Group (UK) Hoare Govett (The Netherlands), Cenkos Securities (UK), Numis Securities (UK) Freshfields (UK) Ashurst (UK)
  • Roberto del Toro Mario Alberto Gutiérrez The real estate markets in cities and towns all over Mexico have expanded in the last few years. The trend is particularly motivated by the improvements in the country's domestic economy, which has increased the demand for goods and services.
  • Laurent Grençcon Samanatha Nonnenkamp Specialised Investment Fund regime enters into force The law creating the Specialised Investment Funds (SIFs) and replacing the law on institutional investor funds entered into force on February 13 2007. From a regulatory point of view, SIFs enjoy more flexibility than other Luxembourg undertakings for collective investments. Institutional investors, professional investors and well-informed investors (including high net-worth individuals) can make use of this investment vehicle.
  • Bob van der Made On February 26 2007, the European Commission announced that it had adopted new EU-wide guidelines on advance pricing agreements (APAs) aimed at avoiding transfer pricing disputes and increasing legal certainty for companies. Resolving international tax disputes has become a major issue for businesses and tax administrations in Europe and they have increased both in number and complexity, and this trend is expected to continue. An APA is an agreement between a tax administration and a taxpayer on how future transactions between associated companies established in two or more EU member states will be taxed.
  • Frank Schmidt A small business purchased a generic internet domain name, based on the name of a river, from the previous registrant, an internet service company.
  • Leslie Morgan Paul Stepak On February 21 2007, the proposed enhanced gross-up and dividend tax credit for eligible dividends received by a domiciled individual after 2005 from a corporation resident in Canada became law. For a dividend to be considered eligible, the entire payment must be designated as such to each recipient in writing at the time it is paid. At present, there is no ability to designate a dividend after it is paid. While the Canada Revenue Agency has indicated that a number of ways are acceptable for a public corporation to designate an eligible dividend, such as posting a notice on the corporation's web site, issuing a press release or making a statement in corporate quarterly or annual reports, no such leeway is given to a non-public corporation.
  • The Bank of China's Hong Kong HQ: tax parity will give more domestic taxpayers the chance to reach the Bank's heights The National People's Congress (NPC), China's legislature, voted today to remove tax breaks for foreign companies.
  • Neil Wilson May 17 2007 witnesses the passing of 25 years since Royal Assent was given to Australia's transfer pricing rules, as introduced by the then federal treasurer, John Howard.
  • On February 16 2007, law No. 20,171 was published, which will increase the foreign tax credits available to Chilean investors in respect of certain payments received from outside the country.