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The ECJ judgment in Marks & Spencer will have an impact on the decisions to be taken by multinational groups with subsidiaries in different EU countries. Lovells' international tax team analyzes how various member states might deal with the verdict

Taxpayers should be aware that time may still be on their side if they wish to make similar claims to Marks & Spencer. An analysis of other tax cases from the UK courts shows what is possible, explains Simon Whitehead of Dorsey & Whitney

The technical corrections legislation passed at the end of 2005 in the US will have an impact on international tax. Marjorie Rollinson and Michael Mundaca of Ernst & Young explain how this and budget reconciliation, yet to be agreed, will affect taxpayers in 2006

The Mexican Congress passed thin-capitalization rules in 2005 to stop taxpayers using excessive debt to avoid tax. Roberto del Toro, David Cuellar and Francisco José Zamora of PricewaterhouseCoopers explain how the rules were relaxed in 2006

China and South-East Asia offers investors a wide range of potential business locations. In the first of two articles, Steven Herring of RSM International examines the tax issues when investing in China, Hong Kong, Indonesia and the Philippines

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M & A Undisclosed IBM, US Bowstreet, US Cravath, Swaine & Moore, Sharon Mendelson, Jeffrey Mande (US) Goodwin Proctor, US M & A $4.8 billion Lottomatica S p A GTECH Holdings Corporation Dewey Ballantine, Gordon Warnke and John Apadula (US) Cravath, Swaine & Moore, Michael Schler, Sean Thompson M & A €218 million ($267.7 million) Grosvenor Group 17% of Sonae Sierra, Portugal Slaughter and May, Graham Earles, Simon Letherman, KPMG (UK) In-house tax M & A Undisclosed Group AXA, France AXA Konzern AG (in connection with a voluntary public acquisition offer) Clifford Chance, Stefan Behrens, Germany M & A £37 million ($66 million) JS&P Holdings Towry Law from Henderson Group Slaughter and May, Paul Fahy (UK) Eversheds, Emma Channon (UK) M & A £143 million ($255 million) Unnamed Spanish investor Deka Immobilien's freehold interest in 100 Wood Street, London Clyde & Co PricewaterhouseCoopers M & A About €6.9 billion ($8.5 billion) Macquarie Infrastructure Group (MIG) and the Eiffage-Macquarie consortium Autoroutes Paris Rhin Rhône (APRR) Clifford Chance, Eric Davoudet, Anne de Dietrich (France) advised Macquarie Infrastructure Group (MIG) and the Eiffage/Macquarie consortium, Bredin Prat advised Eiffage and the Eiffage/Macquarie consortium Willkie Farr & Gallagher and Freshfields Bruckhaus Deringer (France) M & A Undisclosed Symantec Corporation (US) Imlogic (US) Fenwick & West, Ronald Schrotenboer and Adam Halpern In-house tax M & A $518 million Johnson & Johnson Animas Corporation Cravath, Swaine & Moore, William Brannan, Sharon Mendelson Pepper Hamilton Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Collateralized loan obligation (CLO) £5 billion ($8.9 billion) Barclays Bank Simmons & Simmons Clifford Chance (UK) Exchangeable bond Issue €572.8 million ($703.1 million) Parapública (Participações Públicas (SGPS)) Citigroup Global Markets and Caixa - Banco de Investimento Morais Leitão Uría Menéndez, Filipe Romão (Portugal) Initial public offering £150 million ($267.5 million) QinetiQ Group Credit Suisse, JPMorgan Cazenove and Merrill Lynch Herbert Smith Freshfields Bruckhaus Deringer, Jonathan Cooklin, Mark Boyle (UK), Claude Stansbury (US)

A plan to make Canberra, the capital of Australia, a tax haven has been rejected by Jim Lloyd, the federal territories minister, and Ted Quinlan, the treasurer of the Australian Capital Territory, where Canberra is located. Under the plan Canberra would no longer pay income tax, higher education contribution scheme, company tax, luxury car tax or fringe benefit tax. The only taxes that would remain would be the goods and services tax, the Medicare levy, superannuation guarantee levy and beer and spirit excise.

The tax team of Barros & Letelier, a law firm in Santiago, has moved to PricewaterhouseCoopers in the same city. Led by Francisco Selamé, it also comprises Astrid Schudeck, Francisca de la Maza and Sandra Benedetto.

The codification of the economic substance doctrine in the US Senate's tax reconciliation legislation may have significant ramifications for bona fide business transactions that are far removed from the tax shelter transactions that are the intended target of the legislation, according to the American Bar Association's Section of Taxation.

Robert Green has left the US Internal Revenue Service to become a member of Caplin & Drysdale's international tax practice in its Washington, DC office. As director, international at the IRS, he was responsible for the US' cross-border negotiations and controversies with its treaty partners and dealt with other issues such as cost sharing.