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  • Corporate attitudes to tax risk in the UK have changed significantly over the past two years according to a Deloitte survey of 90 tax directors from FTSE 350 companies.
  • The Supreme Court of Canada has released its decisions on the first cases heard by it involving the general anti-avoidance rule (GAAR) enacted in 1988. The Supreme Court dismissed the Canada Revenue Agency's (CRA) appeal in The Queen vs Canada Trustco Mortgage Co and also dismissed the taxpayers' appeals in Kaulius vs The Queen.
  • On July 1 2005 the Austrian EU Withholding Tax Act (EU-Quellensteuergesetz) came into effect. The Act implements the EU Savings Directive (2003/48/EC).
  • The IRS has announced that taxpayers may come forward and settle a range of 21 transactions that it considers to be abusive.
  • Non-residents are increasingly using unlimited liability companies to structure Canadian investments tax efficiently. McMillan Binch Mendelsohn and Honigman Miller Schwartz and Cohn explain the advantages offered by the use of such entities
  • The major attraction for the development of special economic zones and units within a zone in India is the direct and indirect tax relief available, reveal Jairaj Purandare, Prashant Deshpande and Kanwal Gupta of PricewaterhouseCoopers
  • Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A Undisclosed Landsbanki Kepler Equities S.A. (Lightyear Capital - controlling shareholders) Allen & Overy, Patrice Couturier, UK Simpson Thacher and Bartlett (For Lightyear Capital) M&A €440 million One Equity Partners Vacuumschmelze GmbH & Co. KG Allen & Overy, Volker Balda, Holger Erwin, Tobias Ackert, Germany M&A Undisclosed DIS Deutscher Industrie Service AG acquired 60% of CST Group CST Group PricewaterhouseCoopers Laudien & von Nottbeck and Dr. Wennekers und Partner M&A £80 million Apeejay International Tea Limited Premier Foods, Typhoo, London Fruit & Herb, Lift Berwin Leighton Paisner, Richard Harbot, London, BDO, David Beck Weil Gotshall & Manges, Sarah Priestley and Jane Scobie, UK M&A €1.3 billion Tele2 / Apax Partners Versatel Telecom International NV PricewaterhouseCoopers, Netherlands, Hans Seeling, Marius Möller, Machiel Visser Versatel In-house Tax department M&A €440 million Kuehne + Nagel International AG ACR Logistics Clifford Chance, Douglas French and Shimaela Anwar, London Baker & McKenzie M&A Undisclosed NextiraOne GFI Informatics Limited from GFI Informatique S.A. of France Jones Day, Lisa Anderson, UK Eversheds, Janet Jones, UK M&A £478 million SABMiller Backus of Peru Lovells, Daniel Friel, UK In-house M&A $1.3 billion Eniro Findexa Bird & Bird Cleary Gottlieb, Steen & Hamilton M&A €840 million EnBW Energie Baden-Wurttemberg EVN AG EnBW in-house, Ingo Voigt, Germany Cerha Hempel Spiegelfeld Hlawati, Albert Birkner, Clemens Hasenauer, Germany Ernst & Young Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Bond Issue £2.26 billion HBOS's master trust Mound Financing Citigroup, Deutsche Bank and Lehman Brothers Allen & Overy, Mark Brailsford, Amrit De Hal, Steffan Adfeld, UK, Arnold & Porter, Michael Rufkahr, Joy Taylor, US Herbert Smith, Howard Murray, Robert Young, UK Financing €455.2 million Regasificadora del Noroeste, S.A BBVA and Caixa Galicia Uría Menéndez. Juan I. González (partner) and Cristina Navarro (associate Lovells. Madrid IPO €1 billion Telnet P Morgan Securities Ltd., KBC Securities NV/SA , Lehman Brothers International (Europe), Merrill Lynch International, Goldman Sachs International, Dexia Bank NV/SA, Petercam NV/SA and Fortis Bank NV/S Cleary Gottlieb, Frederieke Compernolle, Belgium Allen & Overy, Patrick Smet, Belgium
  • Germany's new coalition government has postponed outgoing chancellor Gerhard Schröder's planned effective corporate tax cut from 38.7% to 32.7% from the beginning of next year to 2007, making it part of a broader package of tax reform. German press reports also claim the coalition plans to raise the value-added tax (VAT) rate from 16% to 18%.
  • Barclays announced on October 21 that it has appointed Dario Garcia as the new global head of value-added tax (VAT) in London.
  • George Osborne, opposition chancellor of the exchequer, or finance minister, in the UK, has launched a tax reform commission aimed at improving the economic efficiency, transparency, simplicity and fairness of the British tax system.