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The Exodus acquisition marks the end of a restructuring process at Cable & Wireless that has seen the company transformed from consumer telecoms provider to business internet protocol (IP) and data provider in little over two years. And while the company's tax group has been kept busy with numerous transactions throughout the transformation, it too has been restructured.

DATE TYPE OF DEAL VALUE TARGET ACQUIRER/ ISSUER HOLDER/ UNDERWITER ADVISERS TO TARGET ADVISERS TO ACQUIRER/ ISSUER ADVISERS TO HOLDER/ UNDERWRITER 28/2/02 disposal £560 million ($796 million) Malibu Allied Domecq (UK) Diageo (UK) n/a Linklaters, London, Guy Brannan, Guy Dingley, Clare Carpenter; New York, Valerie Leipheimer; in-house Michael Kennedy Slaughter and May; London Steve Edge, Charles Goddard 3/3/02 disposal £250 million ($355.7 million) Land Securities (UK) client of REIT Asset Management (UK) n/a Nabarro Nathanson, London, Nick Burt n/a n/a 6/3/02 sale and

The French tax authorities have issued new guidelines (Instruction 4 J-1-02, January 3 2002) on the provisions of the Finance Bill 2001 that reduced the rate of the avoir fiscal for tax credits used in 2001 and 2002. In particular, the authorities comment on these provisions with regard to the situation of non-French residents.

Budget 2002/03

Acquirers of German property-owning companies are obliged to notify the authorities of any transactions that may trigger German real estate transfer tax. The consequences for investors and their advisers who fail to do so may be serious. By Hans-Jörg Fischer, Deloitte & Touche, Frankfurt and Martin Paul Wassmer, University of Freiburg

Article 8 of the India – UK tax treaty governs the taxation of profits derived from the operations of aircraft. A recent ruling of the Appellate Tribunal gives a detailed interpretation of key tax treaty provisions. By K R Girish, RSM & Co, Bangalore

Big business has welcomed a package of company-friendly tax changes announced by the UK chancellor of the Exchequer

Investments in information technology can make all the difference to a company’s returns. Integrating tax strategies into these investments can supercharge their returns and lead to further competative advantages. By Jacqueline Doonan, Keith Reams and Cristina Magalhães, of Deloitte & Touche, San Francisco

The Dutch Supreme Court issued a decision on February 8 2002 that interprets the ?reasonable taxation? requirement under the Dutch abuse of law (fraus legis) provisions (Case No 36 358). The case involved the deductibility of interest for Dutch corporate income tax purposes when a Dutch company paid the interest to an Irish limited company benefiting from the Irish International Financial Services Company (IFSC) regime. Dutch tax law contains a number of measures to prevent erosion of the Dutch tax base. The tax authorities frequently have sought to use these rules to deny Dutch companies interest deductions on certain types of intra-group loan transactions that are considered to have been entered into with the primary purpose of eroding the tax base. In such cases, interest would only be deductible if the transaction was carried out for valid business purposes or if the interest was subject to, and actually taxed at, a ?reasonable? rate in the country of residence of the recipient.

Gordon Brown, the UK chancellor of the Exchequer, has released news of business tax breaks that could be worth up to £600 million ($853.5 million) a year. The news came on March 26, three weeks ahead of the scheduled UK budget announcement. Among the new measures, Brown announced tax relief on the cost of intellectual property, initially worth £200 million a year, rising to £350 million a year in the future. The government is also to introduce tax exemption for sales of significant shareholdings, expected to be worth approximately £150m a year to business. Furthermore, large companies will benefit from research and development (R&D) tax credits.