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Glaxo Wellcome and SmithKline Beecham have proposed a merger that would create the world's largest pharmaceutical group and the world's third-largest company after General Electric and Royal Dutch/Shell. The deal is worth £100 billion ($160 billion).

The US Internal Revenue Service has signalled its intention to limit the tax advantages available to some hybrid branches. Joseph DeCarlo of Price Waterhouse LLP, and Alan Granwell and Dirk Suringa of Ivins, Phillips & Barker, Washington DC report

A comparative approach is adopted in this assessment of Italy’s realistic potential as a holding company location. By Piergiorgio Valente and Marco Magenta, Studio Associato Legale Tributario (associated with Ernst & Young International), Milan

For the first time, Deloitte Touche Tohmatsu has released its worldwide tax fee income results.

ICI has taken its case for consortium relief to the European Court of Justice. The Advocate-General’s opinion may not satisfy ICI, but it does imply the liberalization of consortium relief for EU businesses. By Murray Clayson of Freshfields, London

An international group of investigators is said to be examining the tax affairs of global media group News Corporation. The rumoured investigation is thought to involve senior tax investigators from tax authorities in the UK, US, Australia and Canada. A spokesman for the UK's Inland Revenue would neither confirm nor deny the story, adding that the affairs of individual companies are never discussed. However a prominent international tax lawyer has told International Tax Review that even if there is as yet no investigation, the adverse publicity will probably ensure one.

Switzerland's consumer products group Nestlé is to purchase the Spillers pet food business from UK food group Dalgety. The deal is worth £715 million ($1.2 billion) and is still subject to regulatory clearance. The acquisition will give Nestlé 20% of Europe's branded pet food market.

Scottish Equitable has disposed of Aegon Financial Services Group to the UK's Life Assurance Holding Corporation for an undisclosed sum.

EC Tax Law

Failure by a member state to fulfil obligations — Directive 90/434/EEC — Failure to transpose.