France

PwC Société d'Avocats

61, rue de Villiers

92200 Neuilly-sur-Seine

France

Tel: +33 (0)1 56 57 41 33 / +33 (0)6 64 15 47 20

Email: eric.bonneaud@pwcavocats.com

Website: pwc.com/taxcontroversy

Eric Bonneaud is a partner and lawyer at PwC's Neuilly-sur-Seine office.

Eric joined PwC Société d'Avocats, formerly Landwell & Associés, in September 2008.

Eric started his career in 1992 in the French Tax Administration (National and International Tax Audit Directorate) as tax inspector (liquid food-processing and spirits industries), then as head of the automobile and equipment manufacturing industry unit.

In 2002 he became head of unit in the Tax Policy Directorate in the Ministry of Finance, in charge of the negotiation and interpretation of tax treaties, the treatment of mutual agreement and arbitration procedures and French representative within various OECD working groups and the European Union Transfer Pricing Forum. He also acted as French competent authority.

Eric has focused on transfer pricing, international corporate tax and tax treaties. He has gained strong knowledge and experience from his former position in the French Tax Administration for various industry sectors.

Eric holds a master's degree in public law and is graduate in criminal law and from the National School of Tax.

Mayer Brown

20 Avenue Hoche

75008 Paris

France

Tel: +33 1 53 53 51 87

Fax: +33 1 53 96 03 83

Email: lborey@mayerbrown.com

Website: www.mayerbrown.com

Admitted to the Paris Bar, Laurent Borey is one of the five firm practice leaders heading Mayer Brown's tax practice worldwide and is also member of the team leading the Mayer Brown investment fund group.

He is one of France's leading tax lawyers on private equity matters (fund structuring and transaction). He is singled out for his work representing private equity sponsors and his vast experience in the tax structuring of large, complex, cross-border M&A transactions. Laurent also regularly advises prominent entrepreneurs on their personal tax matters and has developed a renowned expertise in tax litigation.

Over the past several years, he has advised and played a key role on many big international deals, with deal values totalling more than $100 billion. These include: Cooper (Charterhouse), Cablevision (Altice), Suddenlink (Altice), NextRadioTv (Group News Participation), Comexposium (Charterhouse), Portugal Telecom (Altice), Express Roularta Group (Altice), Numericable-SFR (Altice), Worldwide Flight Services (LBO France), Labeyrie (LBO France), Elis (Eurazo), Parex Group (CVC Capital Partners), SFR (Numericable), Hamleys (Ludendo) and Vivarte.

Laurent ranks in band one in Chambers Global 2015 and was one of the nominees for the Law 360 MVP award for 2015. He was named Lawyer of the Year in 2014 by the French magazine Option Finance and Tax Advisor of the Year by Magazine des Affaires for 2011, 2014, 2015 and 2017. Laurent is also one of the Mayer Brown practitioners listed in Who's Who Legal and in Who's Who France.

Taj, Société d'Avocats (Deloitte France)

181 Avenue Charles de Gaulle

92524 Neuilly-Sur-Seine Cedex

France

Tel: +33 1 55 61 66 72

Fax: +33 1 40 88 22 17

Email: mguichard@taj.fr

Website: www.taj.fr

Michel Guichard, Deloitte France, is a lawyer and tax partner. He also serves as leader of the Taj indirect tax, customs and tax controversy teams.

Michel has nearly 35 years of experience in international and French tax law. After working for 17 years in the tax legislation department of the Ministry of Economy, Finance and Budget where he was in charge of VAT, customs and international tax treaties, Michel joined Arthur Andersen in 1999. Following that role he joined Taj where he now focuses his practice on counselling French and foreign companies, advising some of the firm's largest clients.

Michel is a member of the International Fiscal Association and APTE, a non-profit organisation of EU VAT experts. He has written articles for many tax publications.

Mayer Brown

20 Avenue Hoche

75008 Paris

France

Tel: +33 1 53 53 43 43

Fax: +33 1 53 96 03 83

Email: bhomo@mayerbrown.com

Website: www.mayerbrown.com

Admitted to the Paris Bar, Benjamin Homo is a partner in the tax practice of the Paris office.

He focuses his practice on advising private equity clients and multinational groups on their acquisitions, mergers and reorganisations and has developed an extensive experience of multi-country transactions. He assists clients on all aspects of the transaction, from tax due diligence to structuring work, including financing matters and management incentives.

In his work on such transactions, Benjamin analyses, develops, and manages complex financial models that allow him to translate multi-jurisdiction tax advice into cash flow simulations, helping clients understand and analyse with their own tools and language the consequences of cross-border taxes on the economics of the transaction.

Benjamin also advises on the creation of French and pan-European private equity funds and assists corporate groups in the day-to-day management of their tax affairs (tax audit/litigation, reporting tools) as well as in the reduction of their global effective tax rate (French and international tax planning, transfer pricing, etc.).

In addition to his native French, Benjamin is fluent in English.

Mayer Brown

20 Avenue Hoche

75008 Paris

France

Tel: +33 1 53 53 43 43

Fax: +33 1 53 96 03 83

Email: clalloz@mayerbrown.com

Website: www.mayerbrown.com

Admitted to the Paris Bar, Christopher Lalloz is a partner in the tax practice of the Paris office.

Christopher advises a large number of French and foreign corporate groups in their acquisition and reorganisation transactions as well as their day-to-day tax management. He also has extensive experience in assisting corporate groups and individuals in the course of tax audits and litigations. His practice also includes fund structuring assistance to French and foreign private equity clients (including the structuring of carried interest rights held by managers) and assistance to individuals on their personal tax issues.

Prior to joining Mayer Brown in 2007, Christopher was a member of a major financial consulting firm in Paris. He also worked for a year and a half in their New York office.

In addition to his native French, Christopher is fluent in English.

Taj, Société d'Avocats (Deloitte France)

181, avenue Charles de Gaulle

92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 40 88 86 75

Fax: +33 1 40 88 22 17

Email: elesprit@taj.fr

Website: www.taj.fr

Eric Lesprit, Deloitte France, was the former head of advance pricing agreements and mutual agreements procedures regarding double taxation elimination at the French tax administration. He has more than 15 years of experience in transfer pricing and international tax with the French tax administration.

Since 1998, Eric worked for the French tax administration regarding companies and individuals' international taxation issues.

He participated in the design and the creation of the APA programme in France in 1999, and negotiated and concluded the first agreements. He led the French APA programme since late 2008. In 2013, he created the new French competent authority, merging the APA programme and the mutual agreement procedures in a single department and constituted the new team. As part of his missions, he was the French administration representative for competent authority procedures with foreign countries, especially those involving transfer pricing.

Moreover, he took part in the legislative drafting process regarding the fight against tax fraud and tax control policy, as well as the management of tax information exchanges and guiding of the French audit directions network.

At the international level, he intervened in the definition of French positions during the European Community and OECD working sessions, especially regarding the fight against tax havens and the negotiation of tax information exchange agreements with non-cooperative territories. He has been deeply involved in the OECD BEPS works.

From 2003 to 2006, he was the technical adviser for the IMF in Washington DC for public revenues (taxes and customs duties).

Eric was educated at the French Tax Administration School.

Eric is working on several projects connected to various sectors of activities, including the pharmaceutical, industrial or financial sectors. He is leading works in APA procedures, mutual agreement procedures, tax audit assistance and international tax strategy.

Taj, Société d'Avocats (Deloitte France)

181 avenue Charles de Gaulle

F-92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 55 61 63 46

Fax: +33 1 55 61 61 04

Email: gmonsellato@taj.fr

Website: www.taj.fr

Gianmarco Monsellato, Deloitte France, is a tax attorney and the global tax and legal leader for client and markets. He is a member of both the Deloitte global tax and legal executive and Deloitte France executive. He was previously the CEO of Taj from 2004 to 2016.

Gianmarco has more than 20 years' experience in international tax and transfer pricing. He advises leading French companies in setting up and managing their global tax policies and defends international companies regarding their French tax controversies. Gianmarco is considered as a thought leader on tax governance and has been consulted several times by the French government. He has published books and articles in France, Japan, the UK, the US and Switzerland.

He is the chairman of the French tax committee of the International Chamber of Commerce, a member of the International Fiscal Association and of the European American Chamber of Commerce. He is also a board member of Fedora, the European Federation of Opera Houses.

He received in 2013 the United Nations 'Women's Empowerment Principles' award, saluting his exceptional championship of gender diversity in the work place.

Taj, Société d'Avocats (Deloitte France)

181 Avenue Charles de Gaulle

92524 Neuilly-Sur-Seine Cedex

France

Tel: +33 1 55 61 69 80

Fax: +33 1 40 88 22 17

Email: pseguin@taj.fr

Website: www.taj.fr

Pascal Seguin, Deloitte France, is a partner and the national leader for tax management consulting. He has more than 32 years of experience, first as a civil servant with the French Tax Administration for 17 years, where he started working in the computerised tax audit/data analytics field in 1986 and in the legal e-invoicing field in 1988. He became an attorney-at-law in 2000 and is now serving some of the firm's largest clients. He specialises in e-invoicing advice, tax audit and computerised tax audit management, and e-archiving strategies.

Pascal is a frequent speaker on e-invoicing and computerised tax audit matters and is regularly consulted by the French Tax Administration when preparing new administrative guidelines regarding these matters.

Pascal is a graduate of the University of Paris in econometrics and in audit and expertise of information systems and digital technologies. He was trained by the French National Tax School (Ecole Nationale des Impôts) and has been a fully qualified certified information system auditor (CISA) since 1992.