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 in public law and is graduated in criminal law and from the National School of Tax

PwC

Crystal Park

61 rue de Villiers

92208 Neuilly-sur-Seine Cedex

France

Direct: +33 1 56 57 45 86

Mobile: +33 6 07 85 46 90

Email: michel.combe@pwcavocats.com

Website: pwc.com/taxcontroversy

Michel Combe is an international tax partner with more than 30 years of experience in advising French and non-French multinationals 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 defense 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 36 24

Fax: +33 1 53 96 03 83

Email: scomis@mayerbrown.com

Website: www.mayerbrown.com

Sabina Comis is a partner in Mayer Brown's private investment funds group. She has a wide–ranging 16 years' tax experience with a strong emphasis on complex tax structuring of international transactions, restructurings and/or refinancings involving multi-sponsors leveraged buy-outs. In addition to her experience in general tax assistance to French and international groups (Molex, Yahoo, Lyondell, Quiksilver, among others), some of her experience includes the Numéricable – Completel acquisition by Cinven and Altice; and the Zodiac acquisition by the Carlyle Group. Financial institutions have also 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, she focuses on the creation and structuring of private investment funds (such as French FCPRs / FPCI and SCRs and European platforms such as SICARs, SIFs or UK LP) with a particular emphasis on private equity 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 the setting up of (i) the first French type endowment fund, (ii) the first French regulated and leveraged investment vehicle for the purchase of discounted debt, (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 modelling of the 'cash distribution article/waterfall mechanism' of the funds documentation. Her clients include Cinven, LBO France / FCT Altercap, The Carlyle Group, Raise Capital, 17 Capital, and HSBC France, among others).

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.

PwC Société d'Avocats – Correspondent Law firm of PwC

61, rue de Villiers

92200 Neuilly-sur-Seine

France

Tel: +33 1 56 57 42 95

Email: pierre.escaut@pwcavocats.com

Website: www.pwcavocats.com

Pierre Escaut, transfer pricing partner, has worked in the PwC Paris transfer pricing group since 1998, and is now in charge of this group.

He devotes all his time to this activity, with extensive experience in documentation, audit defence, and planning work for multinationals.

He has a wide range of industry knowledge including electronics, pharmaceuticals, consumer goods, heavy industry, and luxury.

He started his career in 1990 with the Paris office of Arthur Andersen as a tax lawyer, and subsequently worked within the international department of Bureau Francis Lefebvre where he specialised in international taxation.

He has written a French chapter on transfer pricing published by IBFD.

Pierre graduated from HEC business school and from the Paris Institute of Political Science. He also received a post-graduate degree in tax law at Paris University (Paris-II Assas). He is an attorney-at-law at the Hauts-de-Seine Bar.

Taj

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 is a lawyer and tax partner with Taj, an international law firm and part of the global Deloitte member firm network. 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.

Taj

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 is a registered attorney and CEO of Taj in France, an international law firm and part of the global Deloitte member firm network. He is also Deloitte's global leader for Tax Clients, Markets & Industries. His experience covers a wide range of industries and he advises and defends leading European, Chinese, Japanese, Korean and US multinational companies for their international tax and transfer pricing policies.

Gianmarco has more than 20 years of experience and created the French transfer pricing group. He has led many high profile advance pricing agreements (APAs), competent authority procedures, audit defence procedures, and planning engagements. In addition, Gianmarco has negotiated many successful settlements with the French tax authorities and won a significant French appeal court case restricting the ability of the tax authority to shift the burden of proof onto the taxpayer.

For the past several years, Gianmarco has been heavily involved in enterprise reengineering projects, including many supply chain management and intangible planning engagements. He serves as a strategic tax adviser to CFOs and tax vice-presidents of leading companies. As one of the very few attorneys who have been heard both by the French Senate and the French Congress, he is considered a thought leader on tax governance.

Gianmarco is the chairman of the International Chamber of Commerce's French Tax Committee, and a member of the International Fiscal Association (IFA). He was named a member of the 2008 government commission on tax safety, as well as co-founder of Deloitte's global transfer pricing team. Gianmarco is also joint author of ' Les prix de transfert ' with Patrick Rassat, Maxima editions and 'Transfer pricing, An international guide', Jon Wiley editions, and joint author of ' Cahier du cercle des economistes: Tax strategy of the states ' and 'Companies: Sovereignty and competition'.

Gianmarco won a United Nations' Women's Empowerment Principles (WEP) leadership award in the Business Case for Action Award 2013 category. This event rewarded five CEOs in the world for their exemplary actions in favour of gender equality.

Taj

181 avenue Charles de Gaulle

F-92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 55 61 69 80

Email : pseguin@taj.fr

Website: www.taj.fr

Pascal Seguin is a partner and the national leader for tax management consulting at Taj Société d'Avocats, part of the global Deloitte member firm network. 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 as well as tax audit and computerised tax audit management and e-archiving strategies.

Pascal is a frequent speaker on e-invoicing and computerised tax audits 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 French National Tax School ( Ecole Nationale des Impôts ) and has been a fully qualified certified information system auditor (CISA) since 1992.