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On January 1 Federal Law # 117-FZ of 22 July 2005 came into effect, which introduces certain tax allowances for residents of special economic zones (SEZs). This law is an essential extension of the Law on Special Economic Zones (# 116-FZ of July 22 2005), which governs the creation of SEZs in Russia.

On January 1 2006 the Ministry of Finance introduced two new sets of rules relating to the taxation of importation of goods to Poland. In general the purpose of the regulations is to apply a more taxpayer-friendly approach and create rules which would stop Polish importers from making customs clearances in neighbouring countries instead of in Poland. The government decided to make the changes because of the increased interest of Polish importers in the possibilities created by, for example, Czech postponed accounting system, combined with the exemption for supplies within bonded warehouses.

The Tax Arrangement for the Kingdom (the TAK) functions as a tax treaty between the Netherlands, the Netherlands Antilles and Aruba. The TAK limits the Dutch dividend withholding tax to 8.3% in case of a participation of 25% or more.

Effective from December 19 2005 Royal Assent was given to legislation which amends the operation of what is known as the section 23AG foreign employment income exemption.

The Indian Authority for Advance Rulings (AAR) recently examined whether a US pension trust is entitled to claim benefits under the India-US tax treaty for income from the sale of portfolio investments in India.

TEP is the alignment of tax and procurement strategy. The benefits stem from the optimization of indirect and direct tax and the minimization of the risk of not complying with tax legislation, explain Philip Davies and Nick Mühlemann of Ernst & Young

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

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

The use of allowable losses and disclosure, but little on tax reform, featured in the UK government's pre-Budget statement. Gary Richards of Berwin Leighton Paisner warns that the system's complexity might mean that taxpayers will choose to leave the country

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)