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The Tax Amendment Act 2004 (Abgabenänderungsgesetz) has brought about considerable changes in Austria's exit taxation regime

Roger Agnelli, president of Companhia Vale do Rio Doce (CVRD), a Brazilian multinational mining company, has said that the country’s high tax burden could be discouraging billions of dollars worth of foreign direct investment

The UK Inland Revenue announced last Friday that discussions on a new double taxation agreement with China would be held soon and invited representations from interested parties. The existing double taxation agreement has been in place since 1984.

In recent months several well-known publicly-traded corporations have used section 355 tax-free split-offs to redeem out, in effect, large minority shareholders. The Bush administration's financial year 2006 Budget proposals include a proposal to stop, or at least slowdown, the "cash rich D" split-offs.

Brazil has been known for decades to have had strict foreign exchange controls. The government, through the Central Bank of Brazil, has maintained the exchange controls by restricting access to the commercial exchange market to individuals and companies engaged in international trade transactions, repatriation of capital, remittances of dividends, profits, royalties and service fees. Failure to comply with the exchange controls has, as a general rule, precluded the Brazilian payer from making remittances abroad in foreign currency.

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $370 million Johnson & Johnson Closure Medical Cravath, Swaine & Moore, New York, William Brannan, Sharon Mendelson, Jeffrey Mandel, Young Park Morgan Lewis, Philadelphia, Jeffrey Korenblatt M&A $2.2 billion Medco Health Solutions Accredo Health Sullivan & Cromwell, New York, William Indoe, David Passey, Martin Hamilton Alston & Bird M&A $385 million Kelso & Company Insurance Auto Auctions Skadden, Arps, Slate, Meagher & Flom, New York, David Rievman, Pamela Lawrence Endreny KMZ Rosenman, Chicago, Saul Rudo M&A $1.47 billion Yellow Roadway Corporation USF Corporation Fulbright & Jaworski, Houston, John Allender Sullivan & Cromwell, New York, Ronald Creamer M&A $17 billion Federated Department Stores The May Department Stores Company Jones Day, Cleveland, Daniel Hagen Skadden, Arps, Slate, Meagher & Flom, New York, Sally Thurston M&A £1.06 billion ($2.03 billion) Apax Partners Worldwide 3i Group agreed to sell Travelex Freshfields Bruckhaus Deringer, London, Jonathan Cooklin Dechert, London, David Gubbay; New York, Michael Hirschfeld M&A £1 billion ($1.93 billion) Marriott hotels Whitbread agreed to sell its Marriott hotels business. The company will form a 50/50 joint venture with Marriott to hold the hotel properties until they are sold. Macfarlanes, London, Ashley Greenbank Slaughter and May, London, Gillian Wheeler M&A $4.2 billion BAE Systems United Defense Industries Cravath, Swaine & Moore, New York, Michael Schler, David Ware, Grace Lee Gibson, Dunn & Crutcher, Washington, DC, Art Pasternak M&A A$9.2 billion ($7.3 billion) BHP Billiton WMC Resources Blake Dawson Waldron Allens Arthur Robinson M&A £1.1 billion ($2.1 billion) Aviva RAC Slaughter and May, London, Steve Edge, James Quinn, Martin Walker Herbert Smith, London, Bradley Phillips, David Jacob M&A $1.1 billion IBM Ascential Software Corporation Cravath, Swaine & Moore, New York, Patricia Geoghegan, Stephen Gordon, Jennifer Conway, David Dubner Skadden, Arps, Slate, Meagher & Flom M&A €5.5 billion ($7.32 billion) Metrovacesa Gecina Linklaters, Paris, Philippe Derouin Rambaud Martel, Paris, Roland Poirier M&A $3.5 billion Vodafone Telesystem International Wireless Linklaters, London, Andrew Beverley, Sabina Margulies; Prague, Ton Kemp, Dita Sulcova, Paula Hyblova; New York, Stephen Land Fasken Martineau DuMoulin, Montréal, Alain Ranger Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Fund issue £66 million ($127 million) Absolute Return Trust Cazenove & Co Herbert Smith In-house Securitization £2.1 billion ($4.05 billion) British Land Company and the Broadgate companies conducted a refinancing of the Broadgate Estate Morgan Stanley, The Royal Bank of Scotland and UBS Investment Bank Simmons & Simmons Allen & Overy, London, Mark Brailsford, Gareth Banfield Refinancing €515 million ($688 million) Saft Mizuho Ashurst Clifford Chance

Until December 31 2004, Mexican tax law subjected Mexican taxpayers to immediate taxation on income generated indirectly in jurisdictions deemed to be tax havens. A list of countries deemed to be tax havens was included as an appendix to the law.

The following are some of the significant tax proposals recently announced in the Union Budget. These proposals when enacted would be applicable for the tax year 2005/2006.

Germany's corporate and trade tax consolidation rules were significantly modified in 2003. In February 2005, the tax authorities released proposed administrative guidance on the new rules.

The impact of legislative changes, the future of debt pushdown planning and a straightforward methodology for strategic tax planning are considered by Nick Woodford and Christoph Schreiber of PricewaterhouseCoopers. This article was written before the announcement of new rules in the UK Budget on March 16 2005.