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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.

Spain implemented the EU parent-subsidiary directive 90/435 in 1991 with some anti-abuse clauses (under article 1.2 of the directive). These clauses deny a tax exemption on dividends when the majority of the voting rights of the EU parent is directly or indirectly held by companies or individuals that are non-EU residents. This limitation does not apply if:

Despite new CFC legislation in Italy, a lack of EU harmonization means that taxpayers may still use a variety of taxing jurisdictions to get the best rate for their income. By Marco Giuliani, of Professionisti Associati Deloitte & Touche, Milan

The Isle of Man has vocalized its desire to become an e-commerce centre. But what has the government achieved so far? Tim Craine, director of e-commerce for the Isle of Man, reports

Following the recent announcement of the Indian budget, taxation of dividends has shifted from a fixed-rate system to an entity-based system. Time to take stock of the latest developments to determine the best route of investment into India. By Jairaj Purandare and Avinash Narvekar, Andersen, Mumbai

Though the Belgian participation exemption was radically changed five years ago, only now has tax guidance been issued. Jan Muyldermans, Kurt De Haen and Wim Eynatten of PricewaterhouseCoopers, Brussels, set out the details in the first instalment of this two-part article

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.

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