France: Corporate Tax 2016
France has amended its finance bill for 2015 through an amendment in November 2015, to ensure that the county’s tax group consolidation regime aligns with the Court of Justice of the European Union (CJEU) in its decision in the case Groupe Steria SCA v Ministère des Finances et des Comptes publics. Here it was held that French tax consolidation rules violate the freedom of establishment principle laid down in the Treaty on the Functioning of the European Union, as tax-integrated parent companies with subsidiaries established in other EU member states cannot acquire the same tax benefits for dividends which a domestic tax group of French companies can obtain. Such continued changes in the French corporate tax regime have resulted in increased demand for legal tax advice and a burgeoning legal marketplace. This is reflected in our listing of 66 of the most outstanding French practitioners – up from 45 last year – as well as five leading corporate tax expert witnesses.
CMS Bureau Francis Lefebvre stands out in our research with an impressive 13 individuals listed in our corporate tax chapter. Pierre-Jean Douvier comes highly recommended by clients and peers for having “boundless knowledge of tax law” and being “clear-sighted in relation to complex issues”. He advises medium-sized companies and major groups across the industry sectors, public organisations, local authorities and individuals. Stéphane Austry handles major tax litigation on behalf of corporations, having built up a reputation for providing “the highest-quality advice” to clients who draw on his “invaluable experience”. Edouard Milhac is “a key player” in international taxation and transfer pricing, and is known for “getting to the heart of the issue”. Alongside them, Richard Foissac is a “leading authority” on corporate tax law. He “very skilfully” advises clients across industry sectors and is praised for his “meticulously crafted work”. François Rontani is held in high regard for his “exceptional abilities” and “versatile thinking” in relation to complex international tax issues. Julien Saïac is “a sensational lawyer” with particular expertise in international taxation and transfer pricing. According to clients, he “certainly knows his stuff”. They are joined by Bruno Gibert, a former member of the French tax administration and an expert on international taxation and transfer pricing. He receives recognition in our research for having an “innovative way of looking at things, which delivers a fresh approach”. Pierre-Sébastien Thill is widely regarded as “one of the most knowledgeable and experienced” practitioners in the industry, who impresses with his “meticulous attention to detail”. Michel Collet has been described a “diligent professional” and a “well-known name” in international tax law. With a “well-deserved reputation”, Pierre Dedieu has “vast experience” of international taxation and transfer pricing. A further focus of his practice includes the taxation of major real estate operations. Agnès de l’Estoile-Campi is “technically outstanding” and “beyond impressive”. She specialises in the Brazilian tax system, routinely advising multinationals from France and Brazil on their cross-border tax affairs. Bruno Gouthière is a “distinguished expert” in international taxation. He is known for having “sophisticated knowledge” and particularly “broad experience” of this area of law. Joining them is Stéphane Gelin, described as a “savvy and experienced lawyer”, who advises on a wide range of international taxation issues.
Following closely behind in our research is Bredin Prat, with an impressive six practitioners highlighted. Yves Rutschmann is a “splendid professional” who co-leads the firm’s tax team. He is known for providing “insightful advice” on the tax aspects of transactions including M&A, private equity transactions and corporate restructurings. Pierre-Henri Durand has an “impressively broad practice” and is regarded as “one of the very best in France” with “a consummate understanding of clients’ needs”. The “fantastic” Sébastien de Monès has “an outstanding track record” and advises high-profile national and international clients on their most complex tax issues. Edouard Sicot is described as “technically excellent”; he has extensive experience working on transactions in the real estate sector. With over 30 years of experience practising tax law, Renaud Streichenberger co-leads the firm’s tax team and is known to be a “creative and knowledgeable lawyer” who “works exceptionally well with clients”. He has particular expertise of the tax aspects of complex and strategic transactions, advising clients in connection with tax reassessments and tax litigation matters. They are joined by Julien Gayral, who is praised for providing “detail-oriented” legal advice to clients while “keeping in mind the bigger picture”.
Latham & Watkins is home to Olivier Delattre, who is praised for his “analytical skills” and “ability to find the answers to clients’ most complex tax issues.” His practice comprises advising on issues relating to national and international M&A and divestitures, as well as transfer pricing. Xavier Renard’s “eminent practice” includes advising French and multinational groups of companies, investment funds and financial institutions on the tax aspects of M&A, tax consolidation regimes, and taxation of financial products and asset financing transactions. They are joined by Olivia Rauch-Ravisé who is praised for her “high-quality work” and “strong strategic abilities”. She specialises in the taxation of high-yield capital markets transactions financial instruments and structured financings, with particular expertise in tax issues relating to aircraft, rolling stock and other asset financings.
From Freshfields Bruckhaus Deringer, Antoine Colonna d’Istria is “highly recommended as a top tax lawyer in France”. Having built a reputation for providing “the highest-quality advice”, he has designed award-wining tax structures for his international clientele. Alongside him Cyril Valentin has been described as a “specialist in dealing with complex transactions”. He is known as an “insightful adviser”, with particular experience in the taxation of structured finance, securitisations and tax-enhanced financial products. Vincent Daniel-Mayeur is a “highly esteemed” practitioner, who advises a wide range of domestic and international clients including multinational companies, banks and investment funds.
Gauthier Blanluet at Sullivan & Cromwell is “a certain inclusion”. Clients particularly value his “entrepreneurial approach” and “highly sophisticated tax solutions”. Nicolas de Boynes comes highly praised for his “meticulous advice” and willingness to “always go the extra mile” for clients in relation to tax aspects of M&A and structured products. They are joined by Jean-Pierre Le Gall whose “world-class expertise” makes him a “go-to lawyer for clients”. His broad-based practice includes tax-efficient structuring of cross-border M&A.
At Arsène – Taxand, Nicolas Jacquot is held in high regard for being “extremely thorough”. He is also praised for his “commitment to his clients”. Frédéric Donnedieu de Vabres has “a fantastic reputation due to his phenomenal legal skills” according to peers. His practice includes handling acquisitions, reorganisations, and optimisation of the effective tax rate and tax strategy assistance for clients. Olivier Vergniolle co-leads the corporate tax team and is a ““renowned authority on tax management and strategy”. Clients praise him for being “very attuned to clients’ needs”.
Six firms can boast a double listing in our research. At Jones Day the “superb” Siamak Mostafavi focuses his practice on the taxation of financial products and derivative instruments. Widely regarded as a “leader in the field”, his enviable client list includes numerous financial institutions. Emmanuel de La Rochethulon has developed specific expertise in relation to the tax aspects of private finance initiatives and public private partnerships. He has a reputation for being a “truly outstanding, innovative and technically gifted” lawyer, and impresses clients with his “commercial flair”.
From Clifford Chance Eric Davoudet is described as “a consummate professional”. He is known as am “exceptionally creative and instinctive lawyer”, advising and representing clients across a range of industry sectors. The “impressive” Alexandre Lagarrigue is recommended for his “hands-on technical abilities” combined with “practical and authoritative advice”. He specialises in the tax facets of property investments, tax structuring of real estate investment funds and property portfolio restructuring.
Jean-Yves Charriau at Allen & Overy impresses clients and peers with his “sharp handling of complex transactions”, and produces “pragmatic, clear and meticulously worked-out advice”. Mathieu Vignon is regarded as “one of the very finest in France” with “a consummate understanding” of clients’ tax needs.
King & Wood Mallesons is home to Fanny Combourieu, a “distinguished player” in the market. With a reputation for “encyclopaedic knowledge”, she specialises in private equity transactions, the acquisition, disposal and restructuring of companies, and real estate fund structuring. Alongside her is the “highly skilled” Anne Quenedey, who advises large domestic and international groups on defining their tax strategy. She is praised for “anticipating troubles and disputes” before they arise, and having a “diligent approach” to matters.
Willkie Farr & Gallagher is home to the “terrific” Marie-Hélène Raffin, who focuses her practice on group restructuring, M&A, joint ventures and tax consolidation. She regularly advises major corporations and leading multinational groups on complex and strategic tax issues, who praise her for “bringing real value to a case”. Pierre Ullmann stands out in our research for his “commercial know-how”. Described as “hard-working and dynamic”, he is also recommended for his extensive experience of transactions involving construction and real estate investment projects.
Thomas Perrot leads Skadden Arps Slate Meagher & Flom’s French tax group. His practice focuses on domestic and international M&A-related tax matters for listed and non-listed companies, as well as tax issues in connection with finance and financial instruments. Clients praise his “tremendous understanding” of this area of law.
Philippe Derouin recently retired from the partnership at Skadden to set up his eponymous tax boutique. He is a longstanding veteran of corporate tax law and is held in enormously high regard for his “unsurpassed knowledge” and “user-friendly approach”.
Anne-Sophie Coustel at Cleary Gottlieb Steen & Hamilton is distinguished for her “outstanding contribution to the market” and for her ability to provide “a real-world assessment of legal issues and risks”.
At Linklaters Édouard Chapellier is described as “a lawyer like no other”. With a particular focus on the tax structuring of complex cross-border transactions (including LBOs, joint-ventures and real estate acquisitions) clients are impressed by his “high level of commitment, wealth of experience and all-round technical excellence”.
Nadine Gelli heads the Ashurst’s tax department in Paris. She advises on tax aspects of corporate transactions, in particular LBOs, structured finance, debt syndication and real estate projects. One peer notes that she “keeps the bigger picture in mind without losing sight of the detail”.
At Darrois Villey Maillot Brochier, Vincent Agulhon has “abundant experience” in the industry, advising clients on all tax issues in connection with M&A, reorganisations, real estate investments and financial products. He is particularly skilled in handling transactions which have a cross-border dimension.
From Veil Jourde, Christophe Delrieu is a “naturally gifted lawyer” and “as smart as they come”. He particularly stands out in our research for his “excellent client manner”.
Claire Acard at EY Société d'Avocats has an “estimable reputation” for working at the forefront of tax law. Known for providing “consistently dependable advice”, clients are also impressed by her responsiveness.
Niels Dejean from Shearman & Sterling is an internationally renowned practitioner, who clients describe as having “very intricate knowledge of cross-border tax issues”.
Paul Hastings’ Allard de Waal “is a true great”. Described by clients as a having “impressive technical abilities”, he is renowned for his handling of international and domestic funds.
Yann Grolleaud at Villey Girard Grolleaud regularly assists multinational groups establishing themselves in France or in relation to their cross-border reorganisations, with clients praising his “unrivalled technical, strategic and intellectual skills”.
Olivier Dauchez at Gide Loyrette Nouel is described as “one of the best tax practitioners in France”. He is highly recommended for “inspiring confidence” in clients, whom he advises on matters pertaining to domestic and international tax law.
From Taj, Gianmarco Monsellato is “technically brilliant”. As the managing director of the firm, he advises major French and international groups on fiscal governance, and is praised for having “strong analytical skills”.
Norbert Majerholc is head of White & Case’s Paris tax division. He “very skilfully” advises clients in complex matters relating to French and international tax law, group structure reoganisations and M&A. Clients and peers also praise him for working exceptionally well with clients.
At Dentons Jean-Luc Calisti is “beyond impressive”. He focuses his practice on domestic and international tax structuring within the media, real estate and energy sectors. In particular he is renowned for his “extensive expertise in tax litigation before French and EU Courts.
Chauvettax is home to Isabelle Chauvet, known for her “fantastic work ethic”. She is held in high regard for her “phenomenal level of skill” which has given her “wide acclaim in the market”.
Roland Poirier at Brandford-Griffith & Associés is a “thoroughbred expert” in the field, who offers “first-rate advice” and a “client-centred service”. He advises companies on tax matters in the fields of M&A, group reorganisations, issuance of complex financial instruments and real estate law.
Anne-Sophie Kerfant from Orrick Herrington & Sutcliffe offers “a wealth of knowledge and experience” to her clients. She advises French and foreign industrial companies and financial institutions on financing transactions, mergers and acquisitions and restructurings.
DLA Piper boasts Hervé Israël, who has almost 25 years’ experience focusing on the tax structuring of international transactions. He is praised for his “savvy approach” and “superb technical skill”.
From Hoche Société d’Avocats, Eric Ginter has “a wealth of experience” and continues to impress clients and peers with his “great depth of commercial insight”. He has been involved in tax-leveraged asset financing, family assets restructuring and major tax litigation cases, before both the French and European courts.
The “accomplished” Christophe Rontchevsky, at Benichou & Rontchevsky is regularly recommended by respondents. He is known for “providing unique insight into difficult legal matters”.
The “excellent” Stéphane Chaouat at Weil Gotshal & Mangers is the managing partner of the firm’s Paris office. His distinguished clientele include public and private companies, financial institutions, private equity funds and individuals.
Dominique Godet from Archers is the co-founder and partner in charge of the firm’s tax practice. He advises international and national groups in international taxation. He is recommended by peers for being “an innovative and dedicated practitioner”.
Antoine Gabizon heads Fieldfisher’s Paris tax department. He is a specialist in the tax aspects of M&A, acting for a wide range of high-profile clients.
From Mayer Brown Laurent Borey has advised and “played a key role” in many recent high-value international deals. He is recommended for offering “a personal service” and “a high standard of client care”.
Accuracy is home to the “preeminent” Christophe Leclerc, who is “a favourite among clients” for his “commitment and enthusiasm” when working on complex tax disputes. He specialises in consulting on the management and evaluation of complex projects.
The “incredible” Daniel Beaumont at Associés en Finance impresses clients with his “invaluable and wide-ranging expertise”, and ability to “grasp detail incredibly quickly”.
We also recognise Benoît Delaunay, at the Université Panthéon-Assas. He is a revered “thought leader” with a strong reputation in tax law.
Maurice Nussenbaum at Sorgem Evaluation is regularly appears before the court of cassation and the administrative courts. He is known to be “incredibly knowledgeable and articulate”, and clients praise him for his “direct, clear and effective” approach.
Florence Deboissy is a professor at the Université de Bordeaux, and specialises in business taxation. She is described as “a powerhouse of knowledge”, and known for her “talented handling of intricate issues”.