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European tax specialists have said that the opinion of the advocate-general in the Marks & Spencer (M&S) case at the European Court of Justice (ECJ) leaves many questions about the future of international taxation within the EU unanswered.

The UN has set up a new body that will increase the organization's role in international tax issues. Its Economic and Social Council has passed a resolution to set up the Committee of Experts on International Cooperation in Tax Matters, which takes over the role of the UN's Ad Hoc Group of Experts on International Cooperation in Tax Matters.

The UK government launched HM Revenue & Customs (HMRC), the new tax body formed after the merger of the old Inland Revenue and Customs & Excise on April 18 2005.

The US Court of Federal Claims has upheld the taxpayer's claim for a foreign tax credit in the Guardian case. However, the government still has time to appeal the judgment, points-out Ernst & Young

The 2005 South African Budget was not as dramatic in tax terms as some recent ones. However. it still contained a number of significant company tax proposals, explains Anne Bennett of Deloitte

The government of the Netherlands has proposed sweeping corporate tax changes that would lower the country's tax rate and align its international tax rules more closely with EU law. The proposals, released on April 29, would reduce the corporate tax rate from 31.5% to 26.9% and extend loss-relief rules to countries outside the Netherlands but within the EU.

The taxation of Austrian and foreign investment funds is now more similar due to a decision of the Austrian Constitutional Court and the Tax Amendment Act 2004 (Abgabenänderungsgesetz 2004).

The rules preventing the deductibility of certain costs for subsidiaries outside the EU or EEA do not breach European law, according to an Amsterdam court. Gerben Weening and Samad Laghmouchi of Deloitte explain the decision

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A (Leveraged buyout) $11.3 billion A consortium organized by Silver Lake Partners that includes Texas Pacific Group, Bain Capital, Blackstone Group, Kohlberg Kravis Roberts & Co, Goldman Sachs Capital Partners and Providence Equity Partners SunGard Ashurst, London, Richard Palmer; Ropes & Gray, Boston, Chris Leich, Amanda Holt Shearman & Sterling, New York, Laurence Bambino, Don Lonczak M&A Undisclosed Highland Capital Management ING Bank agreed to dispose of ING Capital Management Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders Ashurst, London, Ian Johnson, Alexander Cox, Robert O'Hare M&A £100 million ($188 million) CKX Simon Fuller and Ingenious Ventures agreed to sell 19 Entertainment Baker & McKenzie, London, James macLachlan, James Smith Harbottle & Lewis, London, Glen Atchison, Louise Gordon M&A $1.85 billion IAC/Interactivecorp Ask Jeeves Wachtell, Lipton, Rosen & Katz, New York, Jared Rusman Gibson Dunn & Crutcher M&A $1 billion Goldner Hawn Johnson & Morrison ShopKo Stores Skadden, Arps, Slate, Meagher & Flom, New York, Stuart Finkelstein Sidley Austin Brown & Wood, Chicago, Mary Niehaus M&A $18 billion ChevronTexaco Corporation Unocal Corporation Pillsbury Winthrop, New York, Susan Serota Wachtell, Lipton, Rosen & Katz, New York, Deborah Paul M&A (joint venture) £366 million ($702 million) Joint venture between Consensus Business Group and Tesco Tesco will contribute 12 of its stores and two distribution centres to a Jersey limited partnership owned 50% by Tesco and 50% by Consensus. The stores and centres are let to Tesco on 27-year leases, with Tesco retaining the option to buy them back Consensus was advised by Herbert Smith, London, Neil Warriner Tesco was advised by Berwin Leighton Paisner, London, Charles Goddard, Gary Richards M&A (joint venture) €100 million ($131 million) Terranova Energy Corporation shareholders Ceatesalas, SL, Corporación Eólica CESA, SA and Ceolica USA Corporation Uría & Menéndez, Barcelona, Luis Viñuales Cuatrecasas M&A Undisclosed Albemarle Corporation Akzo Nobel agreed to sell its Spanish catalysts business unit Hunton & Williams Uría & Menéndez, Barcelona, Marc Ciutat M&A £2.8 billion ($5.36 billion) Fortune Brands Pernod Ricard agreed to sell spirits brands including Sauza, Maker's Mark, Courvoisier, Canadian Club, Laphroaig and Teachers Herbert Smith, London, Bradley Phillips, Derek Hill, David Mogford Macfarlanes, London, Ashley Greenbank, Elizabeth Sherwood M&A £7.4 billion ($14.1 billion) Pernod Ricard Allied Domecq Macfarlanes, London, Ashley Greenbank, Elizabeth Sherwood Linklaters, London, Guy Brannan, Lynne Walkington M&A $1.6 billion Shire Pharmaceuticals Group Transkaryotic Therapies Davis Polk & Wardwell, New York, Avishai Shachar, Neil Barr Cravath, Swaine & Moore, New York, Andrew Needham M&A $990 million RR Donnelley & Sons Company The Astron Group Ashurst, London, Ian Johnson, Tom Cartwright Eversheds, London, Bo Kehinde M&A Undisclosed IBM Healthlink Incorporated Cravath, Swaine & Moore, New York, Alyssa Wolpin, Megan Healey Dorsey & Whitney M&A $3.4 billion Adobe Systems Macromedia Cooley Godward, Palo Alto, Robert Miller Fenwick & West, Mountain View, California, Ronald Schrotenboer Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Financing £152.5 million ($286 million) Insight Foundation Property Trust NM Rothschild and Merrill Lynch Herbert Smith Clifford Chance Securitization £1.06 billion ($2.03 billion) The Mall Fund CSFB and RBS PricewaterhouseCoopers Freshfields Bruckhaus Deringer, London, Sue Porter, Peter Cosmetatos Securities issue £350 million ($657 million) Old Mutual UBS Investment Bank and Barclays Capital Slaughter and May Linklaters

Sed Crest speaks with Secretary-General Tjaco van den Hout regarding the role of the Permanent Court of Arbitration in The Hague as an alternative way to resolve international tax disputes