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Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A £426 million ($710 million) Macquarie Bank Saur agreed to sell South East Water Linklaters Freshfields Bruckhaus Deringer, London, Sarah Falk, Piers Curle M&A Undisclosed Sanlam Netherlands Holding Cornhill Insurance has agreed to sell its wholly owned subsidiary Merchant Investors Assurance Company Lovells, London, Lyndsey Bainton Slaughter and May, London, Graham Earles, Charles Goddard, Hilary Barclay M&A $14.8 billion Manulife Financial Corporation John Hancock Financial Services Simpson Thacher & Bartlett, New York, Steven Todrys Stikeman Elliot, Montreal, Robert Hogan; Sullivan & Cromwell, New York, Ronald Creamer M&A £2.51 billion ($4.16 billion) The Blackstone Group Scottish & Newcastle's managed retail business Simpson Thacher & Bartlett, London, Meredith Jones; New York, Gary Mandel Freshfields Bruckhaus Deringer, London, Sarah Falk, Peter Cosmetatos M&A £1.14 billion ($1.89 billion) Guardian Media Group Trader Media Group sold their remaining shares to Guardian Media Group who already owned 46% PricewaterhouseCoopers, Manchester, Jeremy Rayner, Steve O'Brien Eversheds, Birmingham, Janet Jones M&A $420 million Leonard Green & Partners LP FTD Latham & Watkins, Chicago, Joseph Kronsnoble, Geraldine Pellerin; Los Angeles, Laurence Stein Jones Day, Dallas, Dennis Drapkin; Chicago, Edward Purnell, William McKay M&A Undisclosed Hamsard 2353, the holding company of QS Group BeWise Group Jones Day Gouldens, London, Caitriona McGonagle BPE Solicitors Type of deal Value Issuer Lead managers Adviser to issuer Adviser to lead managers Bond issue £80 million ($134 million) Werretown Supermarkets Securitisations, a special purpose vehicle of British Land UBS Simmons & Simmons, London, Edward Troup Allen & Overy, London, Mark Brailsford, Vimal Tilakapala, Daniel Lewin Stock Offering ($133 million) Applied Films Corporation Citigroup Global Markets and CIBC World Markets N/A Simpson Thacher & Bartlett, New York, Rachelle Holmes Revolving credit facility £200 million ($333 million) House of Fraser HSBC Bank Slaughter and May, London, Steve Edge Linklaters, London, Stephen Taylor Securitization Undisclosed Home Credit Finance Credit Suisse First Boston Simmons & Simmons, Rotterdam, Peter de Brock Clifford Chance, Prague, Vlad Petrus; Amsterdam, Frank de Vos, Willem Trip, Philippe Steffens Securitization £210 million ($350 million) Priory Group Royal Bank of Scotland and Barclays Capital Clifford Chance, London, Michael Wistow, Etienne Wong, Judy Baker Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders, Sinton Clancy Securitization $1 billion Barclays credit card securitization of Q3 by the Gracechurch Trust Barclays Capital Clifford Chance, London, Stephen Shea, Etienne Wong, Alice Gamble, Alex Beattie; New York, John Lutz Weil, Gotshal & Manges, London, Andrew Norwood IPO $297.5 million Journal Communications Morgan Stanley & Co and Robert W. Baird & Co Foley & Lardner, Milwaukee, Jamshed Patel Simpson Thacher & Bartlett, New York, John Creed, Michelle Nadler Ingber Bond issue £300 million ($501 million) Hilton Group Deutsche Bank, Barclays Bank and Société Générale Slaughter and May Linklaters, London, Stephen Taylor

The Dutch Ministry of Finance published draft legislation introducing thin-capitalization rules on October 13. The move brings the country's tax position inline with the European Court of Justice ruling in the Bosal Holding case.

In a landmark judgment (Union of India v Azadi Bachao Andolan), the Supreme Court of India has upheld the validity of Circular 789 dated April 13 2000 issued by the Central Board of Direct Taxes (CBDT) clarifying that a Certificate of Residence issued by the Mauritian authorities would constitute sufficient evidence for accepting the status of residence as well as beneficial ownership for claiming benefits under Indo-Mauritian Double Taxation Avoidance Agreement (DTAA).

The European Court of Justice (ECJ) rendered its decision in the matter of Bosal Holding BV on September 18 2003 (C-168/01). The central issue in Bosal was whether an EU member state may deny a deduction for costs incurred by a domestic parent company with regard to a foreign EU subsidiary (to finance the shareholding for example) where neither the foreign subsidiary's profits nor the dividends it pays are subject to tax in the parent company's home jurisdiction.

The Hungarian Finance Ministry submitted the government's draft 2004 Budget on October 1 2003. The document proposes raising revenue next year through VAT hikes and new taxes, but still envisions a fiscal deficit of 3.8% of GDP next year.

The first draft of the new 2004 State Budget Bill that has been made public contains a couple of relevant changes to the rules on thin capitalization and controlled foreign corporations (CFCs). The changes are the direct consequence of recent European Court of Justice case Lankhorst-Hohorst (thin capitalization) and European Commission actions (CFCs).

On September 30 2003 the European Court of Justice (ECJ) ruled that certain obligations imposed by Dutch law on companies formed abroad but having their principal place of business in the Netherlands are incompatible with EC law (case c-167/01, Inspire Art Ltd).

By virtue of the principle of non-interference in the management of companies (French Administrative Supreme Court, July 7 1958), French tax authorities are not allowed to assess the opportunity of a management decision in the place of the company manager. However, this freedom of management must be exercised within the limitations laid out by the theory of the abnormal act of management: only expenses incurred in the interest of the company are deductible for tax purposes.

After rumours that the Chinese government would amend the VAT refund rates for export sales, the Ministry of Finance and the State Administration of Taxation jointly issued Notice on The Adjustment of Export Refund Rate (the Notice) on October 13 2003. The Notice sets out new VAT export refund rates as well as structural changes. The changes to the refund rates are designed to enhance China export trade and the mechanism for VAT export refunds. It is also anticipated that the amendments will help to alleviate long-outstanding VAT refund claims and thus reduce pressure on public finances.

Dave Rutges and Eduard Sporken of KPMG give an inside view on when finance companies should seek an advance pricing agreement in the Netherlands