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Clarissa Potter, the new acting senior counsel to the chief counsel of the Internal Revenue Service in the US, moves from another position in the Office of the Chief Counsel, that of special counsel.

As of January 1 2005 the Income Tax Law incorporated new thin-capitalization rules by conditioning the deductibility of interest expense arising from funds received through a loan to a debt to shareholder's equity ratio of 3-to-1.

Dutch dividend withholding tax is imposed on dividends distributed by Dutch tax-resident companies. The tax is in principle levied at a rate of 25%. Revenue for the Dutch government amounts to more than €1 billion ($1.182 billion) a year.

In November, there has been a flurry of activity in relation to the progress of cases being heard at or referred to the European Court of Justice (ECJ), as well as considerable activity in the UK domestic courts in relation to EC Treaty litigation.

Indian IT companies are meeting the demand for outsourcing services from US businesses. It makes it essential that to avoid unpleasant surprises they structure their tax affairs properly when they send staff to the US, argues Lloyd Pinto of Grant Thornton

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M & A £2.18 billion Gala Coral Eurobet Ashurst, John Watson, UK Latham & Watkins, UK M & A $2.8 billion Gas Natural SDG SA Endesa SA Freshfields Bruckhaus Deringer, Javier Gazulla and Maria Mera, Spain Clifford Chance, Jose Ignacio Jimenez-Blanco, Spain M & A $1.3 billion St. Jude Medical Advanced Neuromodulation Systems Gibson, Dunn & Crutcher, Stephen Tolles, US Baker Botts, Steve Marcus and James Raborn, US M & A $1 billion Golden Gate Capital Geac Computer Borden Ladner Gervais, Larissa Tkachenko, Canada Blake, Cassels and Graydon, Jeffrey Trossman

Russian companies are becoming more and more attractive to foreign investors. Attention should be paid to tax structuring when deciding on a potential investment. The validity of this statement can be demonstrated by tax analysis of only one transaction: the purchase of Russian companies' shares from the owner. It may appear that the purchase is a simple and tax-neutral operation for the purchaser. Not in Russia, where the odd logic of the Tax Code may put the purchaser in a bad tax position.

A number of international tax-related changes were included in the Revenue Laws Amendment Act and the Revenue Laws Second Amendment Act, which were passed by parliament in November. The change in the participation exemption was dealt with in the November issue, and this update deals with two further amendments.

In October, the German tax authorities issued a form that banks and other unrelated third-party lenders may submit at the request of corporations seeking to avoid Germany's thin-capitalization rules applying to loans they have received.

The GCC states, in their efforts to attract larger volumes of foreign investment, are increasingly willing to enter into and conclude bilateral foreign investment treaties, including bilateral investment treaties, free trade agreements and double taxation agreements. Of particular interest and some debate is the application of tax treaties in the low-tax jurisdictions of Bahrain and the UAE. Bahrain's tax laws only apply to the profits of oil companies, while, within the UAE, although general taxing provisions apply to all businesses, in practice only the profits of oil companies are taxed.