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Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A A$9.2 billion ($7.05 billion) BHP Biliton launched a successful bid for WMC Resources WMC Resources Blake Dawson Waldron, Melbourne, Duncan Baxter, Teresa Dyson, Geoff Mann; Sydney, Richard Dukes, Len Hertzman Allens Arthur Robinson, Melbourne, Sarah Bernhardt, Michael Perez M&A Undisclosed Wizard AcquisitionCo, a company specially formed by The Blackstone Group International, acquired Merlin Entertainments Group International Hermes Private Equity agreed to sell Merlin Entertainments Group International The Blackstone Group International was advised by Ashurst, London, Nicholas Gardner Hermes Private Equity was advised by Linklaters, London, Lynne Walkington, David Sheen M&A £504 million ($913 million) William Hill Organization, a subsidiary of William Hill Stanley Leisure agreed to sell its retail betting operations (including licensed betting offices) in the UK, Northern Ireland, the Republic of Ireland, Jersey and the Isle of Man Freshfields Bruckhaus Deringer, London, Richard Ballard Ashurst, London, Alex Cox Robert O'Hare M&A $620 million eBay Shopping.com Cooley Godward, San Francisco, Robert Miller Fenwick & West, New York, Ron Schrotenboer, Tony Cipriano M&A $460 million Établissements Maurel & Prom Knightsbridge Petroleum agreed to sell the holding companies of its Colombian and Venezuelan assets Willkie Farr & Gallagher, Paris, Philippe Grudé Lawrence Graham, London, Robert Field, Jonathan Legg M&A Undisclosed Merger of BAE Systems Avionics and Galileo Avionica to form a new avionics business and the dissolution of AMS, a 50:50 joint venture between BAE Systems and Finmeccanica N/A BAE Systems was advised by KPMG, London, Caroline Austin, Claire Barker; Linklaters, London, Ian Bowler, Elliot Weston, Ben Ferry Finmeccanica was advised by Allen & Overy, London, David Lewis, Miles Perryman M&A Undisclosed Torreal S.C.R. Richemont agreed to sell Hackett Farrer & Co, London, Peter Davis Slaughter and May, London, Sara Luder, Sara Stewart M&A Total transaction value: €17.2 billion ($20.8 billion) Weather Investments II S.a.r.l, an entity owned by members of the Sawiris family and represented by Naguib Sawiris, Chairman and Chief Executive Officer of Orascom Telecom Holding Enel agreed to sell Wind Telecommunicazioni Weather Investments II S.a.r.l was advised by Dewey Ballantine, Milan, Luca Dezzani Studio Chiomenti, Milan, Ugo Tribulato, Michelle Carpinelli M&A $221 million ScanSoft Nuance Communications Wilson Sonsini Goodrich & Rosati, San Francisco, David Gerson; Reston, Eileen Marshall Fenwick & West, Mountain View, California, Barton Basset M&A $2.1 billion Ripplewood Holdings Maytag Corporation Cravath, Swaine & Moore, New York, William Brannan, Alyssa Wolpin, Darren Heil Wachtell, Lipton, Rosen & Katz, New York, David Einhorn M&A $800 million Coty Unilever agreed to sell its prestige fragrance business to Coty Covington & Burling, New York, Harry Hives, Robert Heller Cravath, Swaine & Moore, New York, Michael Schler, Megan Healey M&A $600 million Groupe Danone agreed to the transfer of its 33% shareholding participation in Mahou using a share capital reduction and a partial sale of shares to the shareholding families Herráiz Mahou and Gervás Sanz Mahou Group Danone was advised by Uría & Menéndez, Barcelona, Juan Antonio Fernández-Velilla Mahou was advised by Freshfields Bruckhaus Deringer, Madrid, Miguel Klingenberg M&A $990 million PR Donnelly & Sons Company The Astron Group Ashurst, London, Ian Johnson, Tom Cartwright Clifford Chance M&A $4.9 billion ProLogis Catellus Development Corporation Mayer, Brown, Rowe & Maw, Chicago, Bruce Gelman, Jeffrey Bruns O'Melveny & Myers, San Francisco, Dean Weiner M&A $2.8 billion ING Clarion Partners Gables Residential Trust King & Spalding Goodwin Procter M&A Undisclosed Société Générale and the other founding member of Infrastructure Investors L.P. 3i Herbert Smith Macfarlanes Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers IPO €540 million ($653 million) TomTom completed an IPO and listing on the Amsterdam Stock Exchange Goldman Sachs International and Lehman Brothers Stibbe, Amsterdam, Stef van Weeghel De Brauw Blackstone Westbroek, Amsterdam, Dick Hofland, Sacha Leeman Securitization £430 million ($783 million) The Scottish Retail Property Limited Partnership secured a loan on two shopping centres, structured in the form of a securitization Eurohypo Simmons & Simmons, London, Nick Cronkshaw, Mark Sheiham Allen & Overy, London, Mark Brailsford, Amrit Dehal IPO $648 million Shanghai Electric Group Company Credit Suisse First Boston (Hong Kong) Limited Freshfields Bruckhaus Deringer, Washington, DC, Claude Stansbury, Emily Antosh Allen & Overy IPO £123 million ($223 million Empire Online Numis Securities Nabarro Nathanson, London, Jim Mottram, Graham Muir N/A Refinancing £515 million ($937 million) Bristol International Airport, which is owned by South West Airports Limited Calyon and Société Générale Clifford Chance, London, David Harkness, Jonathan Kandel, Sara Taylor Ashurst, London, Richard Palmer

Corporate tax directors in the US are weighing up the possibilities for repatriating foreign earnings after the Internal Revenue Service (IRS) issued its latest round of guidance on a Jobs Act 2004 provision that allows companies to bring funds back to the US at a reduced rate of tax.

On July 1 the Philippines Supreme Court announced a temporary freeze on the implementation of the expanded law on value-added tax. The controversial law had caused a rise in fuel prices, which led to petroleum retailers and the airline industry lobbying officials in Manila. The court took note of these efforts, voting 13-2 in favour of a temporary freeze. Hearings on the tax law, which was at the core of President Gloria Macapagal Arroyo's strategy for fiscal stability, will begin on July 26.

The Bangalore Tribunal in the case of Samsung Electronics Company Ltd. vs ITO (2005 93 TTJ 658), held that the payment for purchase of off-the-shelf computer programs for its business use from foreign suppliers, is not royalty taxable in India.

The US Treasury and the Inland Revenue Service (IRS) on June 23 made available the draft version of the 2005 schedule M-3, which deals with income and loss reconciliation for companies with assets over $10 million. They also released instructions for form 1120, the US corporate income tax return.

Under the imputational corporate tax credit system in force in Germany until 2001/02, the double taxation of corporate earnings was avoided by granting dividend recipients - corporations and individuals - a credit for the corporate income tax paid by the distributing corporation. The credit was, however, in general only available with respect to dividends paid and received by a German resident.

The judgment delivered by the European Court of Justice (ECJ) in the Kretztechnik AB vs Finanzamt Linz case is of importance to anyone engaged in value-added-tax-exempt financial transactions - issuing equity or debt for example. The case was directly concerned with value-added tax (VAT) incurred on professional fees related to the issue of shares by the taxpayer on the Frankfurt Stock Exchange. In that case, the Austrian authorities had refused to allow deductibility of VAT on these fees on the grounds that they related to an exempt supply.

The Legislative Decree dated May 27 2005, which is not yet published in the Italian official gazette as of June 30 2005 (the decree) finally implemented Council Directive 2003/49/EC of June 3 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different member states (the directive), whose term expired on January 1 2004.

Belgian value-added tax (VAT) law makes a distinction between "advertising or publicity" costs, (eligible for VAT recovery) and business entertainment costs.

All local and foreign multinational groups must comply with the transfer pricing rules established in article 38 of the Chilean Income Tax Law, which refers to the determination of arm's-length prices charged between related entities on the acquisition or supply of goods and/or services. Within the framework set out by a recent tax authority audit plan on additional tax, a local tax authority can request the filing of two sworn statements.