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News that the UK Inland Revenue has set a target of finding more than three-quarters of people they investigate guilty will radically boost the tax insurance market, according to Composite Legal Expenses.

A decision handed down in early May 2001 by Germany's highest tax court indicates that key provisions of the proposed regulations on transfer pricing documentation requirements have no legal foundation and are therefore invalid. (See articles on the proposed regulations by Alexander Vögele in the January and February 2001 issues of International Tax Review, pp. 38 and 17 respectively.) Further delay in issuing final documentation regulations may now be expected as the Federal Ministry of Finance strives to assess the impact of the Federal Tax Court (FTC) decision on its transfer pricing policies.

While the deregulation of India’s insurance industry is a welcome move, confusion over the tax aspects may prevent it from achieving its full potential. By Subhankar Sinha and Vijay Kumar, PricewaterhouseCoopers, Mumbai

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 25/04/01 partnership undisclosed Granada, Carlton n/a n/a n/a Granada - Lovells, London, Karen Hughes, Conor Delaney; Carlton - Slaughter and May, London, Tony Beare, Jeanette Lloyd n/a 26/05/01 disposal £2.4 billion ($3.38 billion) consortium including Apax Partners and Hicks, Muse, Tate & Furst Yell BT Clifford Chance, London, Robin Tremaine; Andersen Weil, Gotshal & Manges, London, Sarah Priestley, New York, David Bower, Helyn Goldstein, Martin Pollack Allen & Overy, London, David Lewis, Adam Blakemore 29/05/01 acquisition £300 million ($424 million) TotalFinaElf (TFE), Centrica Humber Power Ltd Midlands Electricity, British Energy Clifford Chance TFE - Denton Wilde Sapte, London, Jane Douglas; Centrica - Ashurst Morris Crisp, London, Richard Palmer, Alexander Cox Linklaters, London, Charles Hellier, Conor Brindley 01/06/01 share sale £110 million ($155 million) Unite Group Plc Unilodge Holding Company Cabot Square Nabarro Nathanson, London, Paul Beausang Herbert Smith, London, Howard Murray, Zoe Brown; Andersen, London, Martin Portnoy, Brian White Herbert Smith, London, Howard Murray, Zoe Brown 01/06/01 acquisition £1.2 billion ($1.69 billion) BSkyB Open BT n/a Herbert Smith, London, David Martin, Derek Hill In-house; Andrew Parker, Tim Shaw 01/06/01 acquisition £940 million($1.32 billion) Ti Automotive Holdings Ti automotive division Smiths Group n/a Lovells, London, Daniel Friel Allen & Overy, London, Michael McGowan 01/06/01 real-estate acquisition £280 million ($395 million) Scottish Widows New Square Park MEPC n/a Freshfields Bruckhaus Deringer London, Anthony McWhirter Clifford Chance, London, Etienne Wong, Nina Buchan 01/06/01 tax leasing £500 million ($705 million) Railtrack n/a n/a n/a Clifford Chance, London, Michael Ehrlich, Nina Buchan, Clare McMath, James Plummer n/a 04/06/01 acquisition $1.65 billion Domtar Inc four paper mills Georgia-Pacific Corporation n/a Debevoise & Plimpton, New York, Gary Friedman, Pamela Boorman King & Spalding, Atlanta, Bob Woodward 11/06/01 IPO EUR 914 million ($781 million) Fraport AG n/a n/a n/a n/a White & Case, Frankfurt, Erich Michel 13/06/01 outsourcing deal £2.3 billion ($3.15 billion) Telereal - consortium of Land Securities/Trillium, William Pears outsourcing of telephone exchanges and other properties BT n/a Freshfields Bruckhaus Deringer, London, Michael Thompson, Peter Cosmetatos Ashurst Morris Crisp, London, Susan Crawford, John Cruise; Andersen, London, Andy Rotheray, Lisa McKibben 18/06/01 notes offering $700 million n/a n/a Aetna Inc n/a n/a Davis Polk & Wardwell, New York, Harry Ballan 18/06/01 acquisition $2.9 billion Cedant Corporation Galileo International Inc n/a Jones Day Reavis & Pogue, Cleveland, Edward Purnell, Wade Wagatsuma Skadden, Arps, Slate, Meagher & Flom, New York, James Tandler, Katherine Bristor n/a 19/06/01 joint venture $2.2 billion Teco Energy Inc, Panda Energy International n/a n/a n/a White & Case, New York, Arthur Scavone, Helen Laval n/a 21/06/01 recommended offer £147.1 million ($207.6 million) Johnson Matthey Plc Meconic plc n/a Travers Smith Braithwaite, London, Victoria Nicholl, Jo Walker Herbert Smith, London, Neil Warriner, Nikol Davies n/a 22/06/01 acquisition £570 million ($807 million) General Electric Capital Corp National Mutual n/a Herbert Smith, London, Howard Murray, Zoe Brown PricewaterhouseCoopers, London, Jane Arkle, John Preston n/a

Liechtenstein has been removed from the Financial Action Task Force (FATF) blacklist of countries. The state was the only European country placed on last year's list of non-cooperative countries fighting against money laundering. The Bahamas, the Cayman Islands and Panama were also withdrawn from the blacklist. The decision, announced on June 22, comes after Liechtenstein took a series of measures to deal with the problems.

Dividends received by an operating Swedish company from a foreign company are exempt from Swedish corporate tax if the receiving company holds at least 25% of the voting rights in the distributing company at the end of the tax year, or it is made probable that the shares are held as a trade investment. The foreign company must also be subject to a tax comparable to Swedish tax (that is, a tax levied at a rate of at least 15%).

KPMG has appointed Robert Aland as the midwest leader of the firm's Tax Controversy Services practice and a member of the firm's International Corporate Tax Services practice. Aland will be headquartered in KPMG's Chicago office. At KPMG, Aland will focus specifically on helping large multinational clients address the tax challenges inherent in today's increasingly complex tax environment. His areas of concentration at the firm will include tax controversy services and international tax matters.

Deloitte & Touche has made five prominent new hires across several practice groups in the US. Maurice Emmer joins Deloitte & Touche from Baker & McKenzie in Palo Alto as leader of the Global Earnings Management Initiative. This involves the discipline of cost sharing and the division of functions and risks among taxpayers to achieve an optimum tax result.

Suite 3000, Maritime Life Tower

The Portuguese government has released a revision to securitization laws that will encourage many more deals in the country