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Arnold van der Smeede and Adam Sibarani of Spigthoff discuss the proposals to change the Dutch corporate tax act which were announced at the end of April

Keith O'Donnell and Paul Chambers of Atoz Tax Advisers discuss how the legislature and the courts in Luxembourg and elsewhere have influenced international tax recently

Two recent circulars issued by the State Administration of Foreign Exchange (SAFE), the "PRC State Administration of Foreign Exchange Circular on Relevant Issues in Improving the Administration of Foreign Exchange of Mergers and Acquisitions by Foreign Investors (11)" issued on January 24 2005 and the more recent "PRC State Administration of Foreign Exchange Circular on Several Issues on Registration of Overseas Investments by PRC Resident Individuals and Foreign Exchange Registration of Mergers and Acquisitions by Foreign Investors(29)" issued on April 8 2005, have recently been a current topic of interest for Chinese and foreign investors. The SAFE's concern lies in the establishment of offshore M&A and restructurings by Chinese citizens, otherwise known as "roundtrip investment".

Spain recently enacted a new set of regulations clarifying the tax treatment of certain securities lending transactions. However, this new legislation is unclear and there are several issues open to interpretation, points out Miguel Baz of Lovells

Simon Briault speaks to corporate tax directors to investigate the pros and cons of increasingly long and complicated tax systems

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $7.8 billion SABMiller Santo Domingo Group agreed to sell Bavaria Lovells, London, Daniel Friel; New York, Julie Reynolds Santo Domingo Group was advised by Simpson Thacher & Bartlett, New York, John Creed, Nancy Mehlman M&A $2.1 billion Insight Acquisition Corporation and Carlyle Group Insight Communications Co Debevoise & Plimpton, New York, Peter Furci, Elizabeth Pagel Serebransky The special committee of the board of directors of Insight Communications Co was represented by Skadden, Arps, Slate, Meagher & Flom, New York, Phillip Adams M&A Undisclosed Insight Investment Management gave advice to Insight Foundation Property Trust and The Westbury Property Fund on a joint investment for a 40% stake in a joint venture special-purpose vehicle sold by Delancey Delancey Insight Investment Management was advised by Ashurst, London, John Watson, Kate Eveleigh Olswang M&A Undisclosed Apax Partners España Panrico Ashurst, Madrid, Eduardo Gracia Garrigues M&A Undisclosed Chemring Group Comet Gesellschaft mit beschränkter Haftung, Pyrotechnik-Apparatebau Ashurst, Frankfurt, Nina Siewert In-house M&A £102.5m ($184 million) Lion Capital Ramen Holdings Limited (Wagamama Restaurants) KPMG, London, Paul Megson, Adrian Crouch, Gill Slater Rees Pollock, London, Jonathan Munday; Travers Smith, London, Kathleen Russ M&A $1.59 billion HSBC Finance Corporation Thomas H Lee Partners LP agreed to sell Metris Companies Wilmer Cutler Pickering Hale and Dorr, Washington, DC, William Wilkins Skadden, Arps, Slate, Meagher & Flom, New York, Mitchell Solomon M&A €3.10 billion ($3.87 billion) Adidas-Salomon Reebok International Simpson Thacher & Bartlett, New York, Steve Todrys, Noah Beck; Eversheds, London, Tom Daltry Ropes & Gray, Boston, Loretta Richard; New York, Daniel Kolb M&A €140 million ($171 million) Bidvest Deli XL, a subsidiary of Koninklijke Ahold NV KPMG, London, Andrew Gavan, James Madams; Amsterdam, Marc Kuijlaars Koninklijke Ahold in-house team M&A $240 million Amdocs Limited DST Innovis Cravath, Swaine & Moore, New York, Michael Schler, Lauren Angelilli Skadden, Arps, Slate, Meagher & Flom; Meitar Liquornik Geva & Leshem Brandwein M&A $270 million Pearson Education WRC Media agreed to sell American Guidance Service Morgan Lewis Cravath, Swaine & Moore, New York, Andrew Needham, Annie Kim M&A €1.3 billion ($1.6 billion) Goldman Sachs Pirelli Cables KPMG, London, Andrew Gavan, Martyn Brown PricewaterhouseCoopers M&A Undisclosed InHealth Group BDF Holdings Macfarlanes, London, Ashley Greenbank The selling shareholders were represented by McClure Naismith Anderson & Gardiner M&A £594 million ($1.07 billion) Cable & Wireless Chelys Limited (which owns the Energis business) Slaughter and May, London, Graham Iversen Macfarlanes Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Collateralized Debt Obligation €455 million ($562 million) GSC European CDO II Lehman Brothers International (Europe) Clifford Chance Ashurst Financing €1.36 billion ($1.69 billion) Permira and PAI to finance a bid for Cortefiel JP Morgan, ING Bank London Branch and The Royal Bank of Scotland Linklaters Ashurst Securitization €750 million ($935 million) EFG Eurobank Ergasias completed a credit card securitization with securities issued by Karta 2005-1 Deutsche Bank EFG Eurobank Ergasias was advised by Kallimopoulos, Loukopoulos & Chiotellis Law Firm Clifford Chance IPO C$325 million ($271 million) Royster-Clark and its parent Royster-Clark Group CIBC World Markets, BMO Nesbitt Burns, RBC Dominion Securities, Scotia Capital, National Bank Financial, TD Securities, Canaccord Capital Corporation and Raymond James Torys, Toronto, Corrado Cardarelli; New York, Peter Kennan Goodmans

New Zealand taxpayers have negotiated two significant advance pricing agreements (APAs) - one with Japan by a major produce exporter and one with the US by a leading manufacturer. According to Ernst & Young, which advised on both deals, the bilateral agreements are firsts for New Zealand with each jurisdiction, respectively.

Proposed services regulations and cost-sharing regulations are two of the projects that will interest corporate and international tax directors most in the 2005-2006 Priority Guidance Plan of the US Internal Revenue Service (IRS) and the Treasury Department, which was issued on August 8.

The US Tax Court has published proposed new rules allowing claimants to scrutinize the opinions of special trial judges.

The federal US tax authorities have increased the amount of corporate tax collected by more than 40%. The US government released figures last week that show overall tax revenues were also up by almost 15%.