France

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

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

Admitted to the Paris Bar, Laurent is one of France's leading tax lawyers on private equity matters (fund structuring and transaction). He is popular 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 last few 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 2016 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 and 2015. Laurent is also one of the Mayer Brown practitioners listed in Who's Who Legal and in Who's Who France.

PwC

Crystal Park

61 rue de Villiers

92208 Neuilly-sur-Seine Cedex

France

Tel: +33 1 56 57 45 86

Mobile: +33 6 07 85 46 90

Email: michel.combe@pwcavocats.com

Website: www.pwc.com/taxcontroversy

Michel Combe is an international tax partner with more than 30 years of experience in advising French and non-French multinational enterprises in the management and planning of their local and international tax issues.

He has developed an expertise in international tax structuring and transfer pricing projects including defence work, whether as part of field audits in France and abroad, of mutual agreement procedures (MAP), or at French court level.

His clients are mainly active across the automotive, pharmaceutical and chemical industries as well as in technology, telecommunications and communications, and transport and logistics.

He leads the value chain transformation team for France which assists clients in aligning their tax strategy with their business strategy with regard to structures and flows.

Michel was the managing partner of PwC Société d'avocats from 2009 to 2013.

He is regularly nominated as one of the best French experts in the transfer pricing area including in 2015 by the French professional magazine Décideurs Juridiques.

Michel graduated from the Aix en Provence University of Law in business law in 1982. He also graduated from the HEC MBA programme in 1984.

Michel is a registered lawyer (avocat).

Mayer Brown

20 Avenue Hoche

75008 Paris

France

Tel: +33 1 53 53 43 43

Fax: +33 1 53 96 03 83

Email: scomis@mayerbrown.com

Website: www.mayerbrown.com

Sabina Comis is a tax partner and international co-leader of Mayer Brown's private investment funds group.

She has a wide-ranging 19 years' tax experience with a strong emphasis on complex tax structuring of international transactions, restructurings and/or refinancing involving multi-sponsors leveraged buy-outs. In addition to her experience in general tax assistance to French and international enterprises, financial institutions have relied on Sabina's tax guidance regarding securitisations and on offers and issues of other types of structured financial instruments, such as collateral debt obligations and repo structures.

As a co-leader of the firm's private investment funds group, Sabina also focuses on the creation and structuring of private investment funds (such as French FPCIs, SLPs and SCRs and European platforms such as SICARs, SIFs or UK LP) with a particular emphasis on private equity, venture capital and mezzanine/preferred equity funds.

Her tax experience coupled with her funds experience allows Sabina to advise on tailor-made, often innovative, structures for investments in France, but also throughout Europe, such as setting up: (i) the first French type endowment fund; (ii) the first French regulated and leveraged investment vehicle for the purchase of discounted debt; and (iii) the first dedicated provider of mezzanine and preferred equity financing for private equity portfolios. In addition, Sabina has developed a specific know-how in being able to help clients in the modeling of the 'cash distribution article/ waterfall mechanism' of the funds documentation.

Sabina joined Mayer Brown in 2007 after 10 years of practice with two UK Magic Circle firms, having trained and worked in their London and New York tax teams for four years and in their Paris tax teams for more than five years.

She is fluent in French and English, as well as in her native Italian.

Philippe Derouin, Avocat au barreau de Paris

140, rue du faubourg Saint-Honoré

75008 Paris

France

Tel: +33 1 42 25 88 91

Mobile: +33 6 16 58 11 63

Email: philippe.derouin@cabinet-derouin.com

Website: www.philippe-derouin.com

With more than 40 years' experience, Philippe Derouin is widely respected in the French market, including by international clients and other professionals.

He works as an independent adviser, expert or litigator and is best known for complex tax controversies including before French courts, the European Court of Justice, the European Court of Human Rights and courts in Monaco. He also gives expert opinion in other jurisdictions. Philippe is also highly regarded for his knowledge on tax and corporate law advice on mergers and acquisitions, corporate reorganisations, both in domestic and cross-border contexts. Areas of growth are tax controversy and independent opinion on complex/important transactions.

Throughout his career, Philippe has worked on key merger transactions (Stallergenes/Greer, Match/Meetic, Air France/ KLM, SCOR/MRM, Sanofi/Aventis). He obtained landmark decisions (Alitalia, Roval, Satam, Fonds turbo) and ground-breaking test cases (Golovan/Ukraine, Sudfer) that have been pivotal for French law or have set a precedent.

Philippe has been a member of the Paris bar since 1973. Previously, he has been a partner at three major multinational law firms, namely Gide Loyrette Nouel (1987–99), Linklaters (1999–08) and Skadden Arps Slate Meagher & Flom (2008–15).

Philippe has worked with a number of industry sectors including financial services (Credit agricole, SCOR SE a reinsurance company, The Carlyle group), retail and consumer products (LVMH and Quiksilver), pharmaceuticals and life sciences (Ares life sciences Stallergenes/ Greer, Financiere BioAlfras), professional services (certain members of multinational partnerships), utilities (motorway companies), and mining and metals (Glencore-Xstrata for the Koniambo site in New-Caledonia).

Some of Philippe's clients include Layher (the French subsidiary of a German scaffolding business, in a test case currently pending before the French constitutional court), Stallergenes/Greer (a cross-border merger), Cheetah Mobile Inc. (China), DocuSign Inc. (both cross-border acquisitions), and Parrot (the listed drone manufacturer, in a rights issue).

CMS Bureau Francis Lefebvre

2 rue Ancelle

92522 Neuilly-sur-Seine

France

Tel: +33 1 47 38 42 19

Email: bruno.gibert@cms-bfl.com

Website: cms.law/bfl

Bruno Gibert joined CMS Bureau Francis Lefebvre as an equity partner in 2001 and heads the transfer pricing group that the CMS network put in place within the tax practice. He specialises in international taxation, more specifically in transfer pricing matters.

He has 16 years' experience in the government service, where he was in charge of international tax affairs (negotiation of tax treaties with foreign countries, OECD and EU work, and Competent Authority). He was the co-chairman of the OECD Forum on Harmful Tax Practices from 1996 to 2001. Since 2002, he has been the chairman of the EU Joint Forum on Transfer Pricing and is also a member of the International Fiscal Association (IFA) and chairs the scientific committee of the IFA French branch. He is a member of the IACF (Institute of tax lawyers), and the chairman of the tax committee of the Club des Juristes.

After graduating in political sciences at the IEP Paris (Sciences-Po) in 1979, Bruno completed his education with a master's degree in corporate and tax law at the University of Paris II (Assas) before entering the ENA. Bruno is a French native, who is fluent in English.

Bruno is the author of a report to the French government on tax security in France in 2004 and co-author of two other reports to the French government, one on intangible assets (2006) and one on how to improve the commentary on French tax law (2010). He is also the co-author of the chapter on rulings of a book on French tax procedures (published in 2005 and updated in 2008), a book on transfer pricing in France ('Ed F Lefebvre', 2010) and the author of the chapter on France of the book 'Transfer Pricing and Dispute Resolution' published in 2011, updated on a yearly basis, and of the chapter on the mutual agreement procedure of a book on the OECD Model Convention ('Ed Francis Lefebvre', 2014). He regularly publishes articles on international tax matters in French and international publications.

Taj, Société d'Avocats

181 avenue Charles de Gaulle

F-92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 55 61 66 72

Fax: +33 1 55 61 47 97

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 30 years of experience in international and French VAT 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 newspapers.

Dentons

5 Boulevard Malesherbes

Paris, 75008

France

Tel: +33 1 42 68 47 85

Email: sandra.hazan@dentons.com

Website: www.dentons.com

Sandra Hazan is a partner at the Paris office who practices French and international tax law. Sandra is head of the Europe tax group and co-head of the global tax group.

She is well versed in issues concerning restructuring and tax planning and has a wide experience in assisting clients in tax audits and litigation. While Sandra advises clients on tax issues in all areas of business, she has developed specific expertise in the luxury and cosmetics industry and in the field of private equity, advising both investment funds and investors.

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 Mayer Brown's Paris office.

He focuses on advising private equity clients and multinational enterprises on their acquisitions, mergers and reorganisations. Benjamin has also developed 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.

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 this part of his work, he has handled numerous tax controversy assignments, from the audit phase to court proceedings, including every step of the administrative process. His litigation experience spans a broad spectrum of issues, from VAT or corporate tax claims for French companies to cross-border transfer pricing disputes for US-based multinational enterprises or debt to equity re-characterisation, as well as personal tax litigation. He also has experience in APA negotiation.

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 Mayer Brown's Paris office.

Christopher advises a large number of French and foreign corporate enterprises in their acquisition and reorganisation transactions, as well as their day-to-day tax management. He also has extensive experience in assisting corporate enterprises and individuals in the course of tax audits and litigations. His practice 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 language, Christopher is fluent in English.

Taj, Société d'Avocats

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

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

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 28 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.