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Leading tax executives, advisers and regulators from around the world came to Berlin in September to discuss the latest issues in transfer pricing

The procedures for withholding tax exemption on Japan source income received by foreign corporations and non-residents in Japan have been changed from the "submitting method (teishutsu)" to "presenting method (teiji)".

The Official Journal of the European Union of September 9 2004 contained the European Commission's invitation to submit comments to its letter to the Italian Government of May 7 2004 where it claimed that a certain Italian tax incentive should be treated as an illegitimate State aid pursuant to articles 87 and following of the EU Treaty.

During the ECOFIN meeting of September 10 and September 11 2004, the European Commission presented a non-EU-wide solution for profit determination rules for cross-border companies. This new approach, which is not yet a formal proposal and which arises from the failure to achieve unanimity at the EU level for further harmonization of EU member states' tax laws, will first be studied by working groups.

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $1.25 billion Cendant Orbitz Skadden, Arps, Slate, Meagher & Flom, New York, James Tandler Latham & Watkins, Chicago, Christopher Bennett, Mia DiBella, Brad Faris, Tim FitzSimons M&A Undisclosed Ty Warner Hotels & Resorts Las Ventanas al Paraiso Resort Baker & McKenzie, Chicago, John McLees, John McDonald; Miami, James Barret; Juarez, Jaime Gonzalez-Bendiksen Thompson & Knight; Andrews Barth & Harrison M&A £335 million ($432 million) Punch Taverns agreed to acquire Innspired Group from Alchemy Partners Innspired Group Slaughter and May Macfarlanes, London, Elizabeth Sherwood; Nabarro Nathanson, London, Michael Cant M&A $160 million Yahoo! Musicmatch Skadden, Arps, Slate, Meagher & Flom, Los Angeles, Moshe Kushman, Sandra Strassner Paul Hastings Janofsky & Walker M&A $130 million European Aeronautic Defence and Space Company J F Lehman & Company and Tailwind Capital Partners Kaye Scholer; Clifford Chance Jones Day, London, Blaise Marin-Curtoud M&A ?3.6 billion ($4.5 billion) Lone Star Hypo Real Estate Group agreed to sell a portfolio of real estate loans Mayer, Brown, Rowe & Maw, Frankfurt, Ingo Kleutgens Freshfields Bruckhaus Deringer, Frankfurt, Wilfried Schaefer, Jan Brinkmann M&A $913 million ARM Holdings Artisan Components Davis Polk & Wardwell, New York, Kathleen Ferrell; Menlo Park, Rachel Kleinberg Wilson Sonsini Goodrich & Rosati, San Francisco, David Gerson M&A C$1.4 billion ($1.1 billion) Rogers Wireless Communications Microcell Télécommunications Stikeman Elliot, Montreal, Robert Hogan, Christian Meighen; Pillsbury Winthrop, New York, David Falck Fasken Martineau DuMoulin, Toronto, William Bies M&A ?320 million ($409 million) Candover Partners UCB SA agreed to sell its films business Ashurst, London, Richard Palmer, Kirsty Price Beachcroft Wansbroughs M&A $677 million Fortress Investment Group Stelmar Shipping Shearman & Sterling, London, Bernie Pistillo, Suzette Batista, Leanne Ingledew Kirkland & Ellis, New York, Greer Phillips, Sara Zablotney M&A ?800 million ($1.02 billion) Caja de Ahorros del Mediterráneo StrateStrategic alliance between CAM and AEGON to develop the bank assurance business through Mediterráneo Vida and manage the assets contributed by the parties. Uría & Menéndez, Madrid, Rafael García Llaneza Garrigues Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Bond issue ?180 million ($221 million) Fondiaria-SAI Mediobanca-Banca di Credito Finanziario Ashurst, Milan, Stefano Serbini Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders Notes issue $250 million Human Genome Sciences Merrill Lynch and Credit Suisse First Boston Piper Rudnick, Baltimore, Joseph Langhirt Shearman & Sterling, Washington, Frank Strong, Kristen Garry Notes issue $736 million Calpine Corporation Deutsche Bank Securities Covington & Burling, Washington, William Paul; New York, Alison Wang Davis Polk & Wardwell, New York, Lucy Farr, Laura Iannucci Financing ?497 million ($635 million) TDR Capital The Royal Bank of Scotland provided the financing for TDR Capital's acquisition of Algeco Gide Loyrette Nouel Allen & Overy, Paris, Patrice Couturier

The UK government faces a £3.5 billion ($5.97 billion) bill after the country's Value-Added Tax (VAT) Tribunal referred a mobile phone operators' tax claim on 3G licences to the European Court of Justice (ECJ).

The Israeli parliament gave its initial approval on October 18 2004 to a plan to lower capital gains taxes on foreign securities from 35% to 15%. The planned tax reduction must still pass through two further votes in parliament later this year and will go into effect in 2005 if it is approved.

Wolfgang Tischbirek, a tax partner formerly at US law firm Shearman & Sterling, has joined to P+P Pollath & Partner. Tischbirek left Shearman & Sterling in May 2004, where he was a partner specializing in international tax and mergers and acquisitions.

The Irish Finance Bill 2004 contained a number of measures aimed at increasing the attractiveness of Ireland as a corporate headquarters and holding company (HoldCo) jurisdiction. Broadly these new measures provided for an exemption from corporation tax on gains arising on the disposal of qualifying shares, and a wider double tax relief for foreign taxes levied on dividends received by an Irish resident company.

London law firm Lovells has hired two senior government officials to launch a tax practice in Spain.