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  • After years of international criticism over the lack of a transfer pricing regime, the Netherlands is finally codifying its arm’s-length principle. Proposed documentation requirements increase the administrative burden, so companies should review their arrangements well in advance. Eduard Sporken, KPMG Global Transfer Pricing Services, Amstelveen
  • Singapore has announced a series of tax measures aimed at helping ailing companies through the economic downturn. Deputy Prime Minister Lee Hsien Loong announced the country's second tax package this year, worth around $11.3 billion, in parliament on October 12 2001. The package includes rebates for individuals and corporations as well as property rebates and a reduction in stamp duty rates. Announcing the measures Lee explained: ?We want to encourage enterprise, because the way to recover is for the private sector to create new opportunities and generate more wealth. We also want to reduce business costs so that business can stay afloat and minimise job losses.?
  • Within the EU, proposals by both the Swedish and UK governments for the optimum taxation of digitized products have fallen flat. A workable solution must be found – soon. By Andrew Ball, Deloitte & Touche, London
  • Australia and the US have amended their tax treaty. The treaty protocol was signed on September 27 after several years of lobbying by business groups. Under the terms of the protocol Australian companies will be able to repatriate their dividends back from their US subsidiaries tax free. The protocol is due to enter into force in January 2003 after both countries have formally ratified it.
  • DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 07/09/01 recommended offer £103 million ($146.59 million) Greene King plc Old English Inns n/a Pricewaterhouse-Coopers, London, Anthony Bennett Linklaters, London, Keith Wilson n/a 14/09/01 project finance $125 million Pacific LNG Shipping Ltd (PLS) n/a n/a n/a White & Case, Tokyo, Yasuo Igarashi, Miyuki Ueda, Eric Roose, Linda Ng n/a 17/09/01 outsourcing of property portfolio £2 billion ($2.84 billion) BBC n/a Land Securities Trillium n/a Linklaters, London, Jonathan Evans, Michael Hardwick, Victoria Garton, Liz Cole; WS Burness Freshfields Bruckhaus Deringer, London, Murray Clayson, Angela Savin; WS Brodies 27/09/01 disposal £1 ($1.42) O'Rourke John Laing Construction n/a Freshfields Bruckhaus Deringer, London, Francis Sandison, Simon Skinner Nabarro Nathanson, London, Lydia Simpson; RSMI Robson Rhodes, Helen Riley n/a 07/10/01 acquisition $4.7 billion AT&T Wireless Telecorp PCS n/a Cadwalader, Wickersham, & Taft, New York, Linda Swartz, Jeffrey Ashendorf, Alexander Anderson Wachtell, Lipton, Rosen & Katz, New York, Jodi Schwartz n/a 08/10/01 acquisition $777 million Clear Channel Communications Inc Ackerley Group Inc n/a Dewey Ballantine, New York Gordon Warnke, Joseph Pari, John Apadula, Devon Bodoh; Rubin, Winston, Diercks, Harris & Cooke in-house n/a 08/10/01 disposal $2.9 billion Northwest Natural Gas Co Portland General Electric Co Enron Corp n/a Thelen Reid & Priest, New York, Gregory Pavin, Robert Friedman, Laura Lee Mannino Vinson & Elkins, Houston, Edward Osterberg 09/10/01 acquisition $3.8 billion Royal Dutch / Shell Group; Saudi Refining Inc 44% stake in Equilon Enterprises Llc; 35% of Motiva Enterprises Llc Texaco Inc Weil, Gotshal & Manges, New York, Kenneth Heitner, Michele Jacobsen Vinson & Elkins,Houston, Edward Osterberg; Shell, Dale Erickson; White & Case, Washington, Bruce Davis n/a 11/10/01 acquisition $1.98 billion NBC unit of General Electric Co Telemundo Communications Group Inc n/a Paul, Weiss, Rifkind, Wharton & Garrison, New York, David Sicular Weil, Gotshal & Manges, New York, Martin Amdur, Mary Jean Potenzone, Martin Pollack, Nancy Tong, Michael Tingoli, Lillian Spiess n/a 17/10/01 MBO £200 million ($284.64 million) Kyndal International Limited, West LB JBB (Greater Europe) Jim Beam Brands Worldwide Inc n/a Weil, Gotshal & Manges, London, Gary Richards, Sarah Priestley; New York, Kim Blanchard McClure Naismith, Glasgow, George Frier; Chad Park 18/10/01 bond issue $310 million UBS Warburg shares of Yukos n/a n/a Clifford Chance, Moscow, Irina Dmitrieva; New York, David Moldenhauer, James Graham, London, Gerald Montagu, Douglas French n/a 18/10/01 acquisition $1.3 billion WellPoint Health Networks Inc RightChoice Managed Care Inc The Missouri Foundation for Health Lewis, Rice & Fingersh, St Louis, Lawrence Weltman Simpson Thacher & Bartlett, New York, Gary Mandel Michael Tingoli, Lillian Spiess Blackwell Sanders Peper Martin llp
  • Lovells has poached a KPMG partner to set up a tax group in its Düsseldorf office. Dr Christoph Küppers and an associate from KPMG joined the firm on October 1. He is the fourth German tax partner that Lovells has hired in the last 18 months.
  • Getting to grips with dual listed companies (DLC) mergers – what they are, when they work best and what are the main tax issues – presents new challenges. By Ian Bowler and Lynne Walkington of Linklaters, London, and Keith Tucker of BHP Billiton, London
  • A flurry of tax treaty updates introduce some significant changes, and the Eighth and Ninth Circuits clash over St Jude and Boeing decisions – just some of the items making the news. By Hal Hicks, David Benson and Margaret O’Connor, Ernst & Young, Washington DC
  • Offshore specialist Mourant Group has allied with a corporate, legal and tax boutique to tap an Italian securitization market that has already soared to a record $15.4 billion this year
  • Websites should be excluded from the tax nets of OECD member states, according to a recommendation of the OECD's Tax Advisory Group.