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The enlargement and extension of a multinational advance pricing agreement relating to a financial services company demonstrates the flexibility of the concept as a means of providing certainty for taxpayers, according to KPMG

A recent Authority for Advance Ruling decision in India relating to Morgan Stanley sought to define the presence of a permanent establishment in the context of the arm's length principle, reports Mukesh Butani of BMR & Associates

Joel Walters, the new leader of Vodafone's tax department, tells Ralph Cunningham about the role and how it fits in with the rest of the company

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition undisclosed Lockheed Martin (US) Savi Technology (US) Fenwick & West David Forst, Neal Gordon (US) Acquisition £2.3 billion ($4.3 billion) Consortium led by Netcare Healthcare Holdings (South Africa) and Apax Partners Worldwide (US) General Healthcare Group (UK) Ashurst Ian Johnson, Tom Cartwright (UK) Dickson Minto UK (advising sellers BC Partners) Acquisition $1.4 billion Millipore (US) Serologicals (US) Cravath Swaine & Moore Stephen Gordon, Jeffrey Mandel (US) Slaughter and May UK Hengeler Mueller Germany King & Spalding US Acquisition $3.8 billion Investor group Kerzner International (US) Cravath Swaine & Moore Stephen Gordon, Annie Kim (US) Simpson Thacher & Bartlett US Acquisiton of 26% stake $2.65 billion Emirates Telecommunications (UAE) Pakistan Telecommunications (Pakistan) Norton Rose UAE Allen & Overy Acquisition £71.4 million ($133.5 million) Inchcape (UK) Lind Automotive Group (UK) Slaughter and May UK Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers IPO $5 billion Kohlberg Kravis Roberts (US) Goldman Sachs (US), Citigroup (US), Morgan Stanley (US) Simpson Thacher Bartlett Steve Todrys (US), Linklaters US/ Luxembourg Cravath Swaine & Moore William Brannan (US), Freshfields Bruckhaus Deringer Eelco van der Stok (the Netherlands/ UK) IPO €1 billion ($1.28 million) GRIFOLS (Spain) Morgan Stanley (US) Uría Menéndez UK/ Spain Bond issue $250 million SOCO International (UK) Merrill Lynch (US) Bridgewell (UK) Ashurst Paul Miller (UK) Linklaters IPO £76 million ($142 million) Acertec (UK) Collins Stewart (Channel Islands) Travers Smith UK Ashurst Simon Swann (UK) Listing £58 million ($108 million) African Copper (Botswana) Numis Securities (UK), Dundee Securities (Canada), Raymond James (US), Paradigm Capital (Canada), BMO Nesbitt Burns (Canada) Ashurst Tom Cartwright (UK), Macleod Dixon Canada, Skadden Arps Slate Meagher & Flom US PFI deal £1 billion Barts and the Royal London NHS (UK) Skanska, Innisfree, Equion Clifford Chance Robert Davies (UK)

The Opinion from an advocate-general of the European Court of Justice in the Cadbury Schweppes case hints that the court could follow its recent trend of giving some hope to both national governments and taxpayers at the same time, when its decision is issued at the end of 2006 or early next year.

US tax practitioners believe that the new Subpart F look-through rule for interest, dividends, rents and royalties transferred between controlled foreign corporations (CFCs) will be very significant to US multinationals. The measure was contained in the Tax Increase Prevention and Reconciliation Act of 2005 (HR4297), signed by President George W Bush on May 17.

Peter Costello, the Australian Treasurer, announced measures aimed at providing greater flexibility, streamlining definitions and reducing complexity and compliance costs as part of his 2006/2007 Budget on May 9, though international tax changes were limited and the business community expressed disappointment at the government's tax reform programme.