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  • The Australian and UK governments signed a new Double Tax Agreement on 21 August 2003, replacing the existing agreement
  • The French government has introduced incentives in the 2003 Supplementary Finance Bill to promote the French business environment for executives of multinationals.
  • Abroad reform of the Italian corporate tax system has been carried out by Legislative Decree 344 of December 12 2003, which amended Presidential Decree 917 of December 22 1986 (the Italian tax code or ITC) pursuant to Delegation Law 80 of April 7 2003. The new Italian corporate income tax (IRES) will be effective from the first fiscal year beginning on or after January 1 2004.
  • India's tax authorities need to keep up with international tax trends to protect their income. The introduction of anti-avoidance measures to counteract the harmful tax practices of pro-taxpayer nations would contribute to increasing India's share in world tax collections, according to Sunil Gidwani and Rajat Panikkar of PricewaterhouseCoopers
  • Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $726 million North Fork Bancorporation The Trust Company of New Jersey Skadden, Arps, Slate, Meagher & Flom, New York, Mitchell Solomon Sullivan & Cromwell, New York, David Spitzer, Miriam Elizabeth Paul M&A $120 million Westar Energy agreed to sell its interests in Protection one to an affiliate of Quadrangle Group The Quadrangle Group affiliate agreed to acquire 88% of the outstanding common shares of Protection One Davis Polk & Wardwell, New York, Kathleen Ferrel, Harry Ballan, Roy Caner Simpson Thacher & Bartlett M&A $2.9 billion Henkel KGaA The Dial Corporation Cleary Gottlieb Steen & Hamilton, London, James Duncan, Eric Atkerson Skadden, Arps, Slate, Meagher & Flom, Washington DC, Clifford Gross M&A Undisclosed Frank Russell Company Pantheon Holdings Debevoise & Plimpton, London, Peter Schuur SJ Berwin, London, Dominic Adams M&A $925 million CSL Aventis agreed to sell the Aventis Behring Plasma business Simpson Thacher & Bartlett, New York, Steve Todrys Shearman & Sterling, Munich, Peter Blessing, Jen Zheng M&A £145 million ($267 million) Davis Service Group HSS Hire Service Group Slaughter and May, London, Feiza Jivraj Travers Smith Braithwaite, London, Kathleen Russ M&A ?3.1 billion ($3.9 billion) The Blackstone Group Celanese Simpson Thacher & Bartlett, New York, Gary Mandel, Meredith Jones Shearman & Sterling M&A ?1.4 billion ($1.7 billion) Bain Capital Deutsche Bahn agreed the sale of its Brenntag and Interfer Stahl subsidiaries to Bain Capital Ashurst, Frankfurt, Karl Herkenroth, Karl Stenger; Kirkland & Ellis, Chicago, Jeffrey Sheffield, David Kung, Pratibha Shenoy Skadden, Arps, Slate, Meagher & Flom, New York, Phillip Adams M&A Undisclosed Lazard WestLB agreed to transfer the Panmure stockbroking business to Lazard Herbert Smith, London, Isaac Zailer Allen & Overy, London, David Lewis, Ben Eaton, Jonathan Chapper, Mike Aherne M&A Undisclosed Bankhall Investment Management agreed to acquire the Premier Mortgage Services business from Prudential UK services Premier Mortgage Services Ashurst, London, Henry Franklin, Alastair Ladkin Maclay Murray & Spens, Glasgow, Martyn Jones, Caroline Colliston M&A Undisclosed Ripplewood Holdings and ZelnickMedia Corporation Ripplewood Holdings and Zelnick Media Corporation acquired Time Life, the direct marketing business of Time Simpson Thacher & Bartlett, New York, Gary Mandel, Adam Rosenzweig Cravath, Swaine & Moore, New York, Stephen Gordon, Lauren Angelilli M&A $385 million Novartis Novartis agreed to acquire the adult medical nutrition business of Mead Johnson & Company Shearman & Sterling, New York, Don Lonczak Cravath, Swaine & Moore, New York, Stephen Gordon, David Dubner M&A $2.4 billion FedEx Kinko's Davis Polk & Wardwell, New York, Kathleen Ferrel, Robert Heller Debevoise & Plimpton, New York, Peter Furci M&A $58 billion JP Morgan Chase Bank One Simpson Thacher & Bartlett, New York, Steve Todrys, Jeffrey Mensch Wachtel, Lipton, Rosen & Katz, New York, Adam Chinn, Jared Rusman M&A $1.2 billion Abbot Laboratories TheraSense Skadden, Arps, Slate, Meagher & Flom, Chicago, Louis Freeman Davis Polk & Wardwell, New York, Harry Ballan Type of deal Value Issuer Lead managers Adviser to issuer Adviser to lead managers IPO $168 million Nelnet America Securities and Credit Suisse First Boston Cahill Gordon & Reindel Davis Polk & Wardwell, New York, Harry Ballan, Avrohom Gelber IPO £165 million ($289 million) Alea Group Holdings (Bermuda) Goldman Sachs International and Merril Lynch International Clifford Chance, London, Douglas French, Lisa McDermott Linklaters, London, Simon Marks Notes offering $3 billion Wyeth Citigroup Global Markets and JP Morgan Simpson Thacher & Bartlett, New York, Dickson Brown, Jeff Mensch Davis Polk & Wardwell, New York, Michael Farber, Misty Bailey
  • The government of Brazil has added a section to its provisional measure 135 that increased the rate from 15% to 25% on capital gains earned by a resident or a party domiciled in a low-tax jurisdiction. The rate increase took effect on 1 January 2004
  • The government of Nigeria has accused the multinational oil company Shell of unfairly exploiting tax loopholes. The tax row centres on a reserves addition bonus scheme that offered companies generous incentives for investing in oil and gas. The alleged tax liability could be as much as $333 million.
  • The Belgian government has issued a royal decree implementing the European Commission's Interest and Royalty Directive of June 3 2003 into Belgian domestic law. The decree provides an exemption from withholding tax on interest and royalty payments between related EU companies, effective from 1 January 2004.
  • Big four accounting firm KPMG on January 19 reported double-digit revenue growth for the fiscal year to September 30 2003. Despite a challenging year for the tax and accounting services profession, member firm revenues were $12.16 billion.
  • The drive to prepare tax departments of law firms in Eastern Europe ahead of EU accession is gathering pace. The Warsaw office of US law firm Chadbourne & Parke has hired five tax lawyers from Altheimer & Gray in Poland, which will join the EU with nine other countries on May 1 2004.