France

1-3, Villa Emile Bergerat

92522 Neuilly-sur-Seine Cedex

France

Tel: +33 1 47 38 55 59

Email: stephane.austry@cms-bfl.com

Website: www.cms-bfl.com

Stéphane has been a tax partner at CMS Bureau Francis Lefebvre since 2007. He coordinates the tax litigation and controversy group of the firm on domestic and international tax issues and headed the tax practice group of the CMS network from 2009 to 2014.

Stéphane graduated in political sciences from IEP Paris (Sciences Po) and attended Ecole Nationale d'Administration (French college for top government officials) from 1991 to 1993. He has spent 15 years in top positions within the French government. He was formerly a member of the Conseil d'Etat, France highest administrative court, and was also tax policy adviser to the Minister of Economy, Finance and Industry from 1997 to 2000. He was financial counselor at the French Embassy in Japan from 2003 to 2007.

Stéphane is a recognised expert in handling high profile tax litigation before domestic courts, including France's constitutional court, and international courts such as the ECJ or the ECHR. He also has an extensive experience on international taxation and the interpretation and application of tax treaties.

He teaches tax law and tax litigation at Sorbonne Law School University Paris I Panthéon-Sorbonne and is a regular speaker in conferences and seminars. Stéphane has also written many articles on domestic and international tax issues in French-speaking, English-speaking and Japanese-speaking tax reviews. He is a member of the International Fiscal Association (IFA) and, since 2014, heads the organisation representing tax lawyers in France (IACF). As a member of the international tax group (ITG), Stéphane belongs to the editorial advisory board of International tax law reports (ITLR). He was co-reporter with Michel Collet for France at the IFA annual meeting (2010) on 'Tax treaties and tax avoidance: application of anti-avoidance provisions'. He has been ranked Tax Lawyer of the Year 2010 in France by Best Lawyer.

A French native-speaker, he is fluent in English and speaks some Japanese.

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, Quicksilver, 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.

61, rue de Villiers

92200 Neuilly-sur-Seine

France

Tel: +33 1 56 57 42 95

Email: pierre.escaut@fr.landwellglobal.com

Website: www.landwell.fr

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

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

He has a wide range of industry knowledge including in: 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 worked subsequently 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 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.

1-3, Villa Emile Bergerat

92522 Neuilly-sur-Seine Cedex

France

Tel: +33 1 47 38 41 97

Email: richard.foissac@cms-bfl.com

Website: www.cms-bfl.com

Richard joined CMS Bureau Francis Lefebvre in 1988 and was co-opted as an equity partner in 1998. He has been the chairman of the firm's advisory board from 2009 to 2012. He is an expert in direct taxes, and manages mainly files in the following subject matters: corporation tax for listed and non-listed companies (French and international); personal income tax; real estate and finance taxation for listed and non-listed French and international companies; tax system of semi-public companies and local authorities.

Richard is also specialised in tax litigation and in tax penal claims: he and his team have been assisting for many years several groups, companies and their key individuals, in tax dawn raid procedures (section L 16B of the French tax code) and in tax fraud claims. He pleads in front of the French penal and administrative authorities.

Well known by the French tax administration as a specialist, he has published different articles on these matters.

Richard is a lecturer at the University of Paris I (Panthéon – Sorbonne) and at the University of Nice Sophia-Antipolis. He is also a member of the Tax Lawyers Institute (IACF) and of the French Association for Corporate Legal Advisors (ACE).

Richard holds a postgraduate degree in business law from the University of Montpellier (DJCE). He is fluent in English.

Some recent experience in litigation and dawn raid procedures:

• Several groups, companies and individuals – assistance for many years in tax dawn raid procedures (section L 16B of the French tax code) and in tax fraud claims; assistance during the DRP, disputes at the level of French and European court of the validity of the procedures,

• French real estate listed companies, foreign groups and investment funds – regarding permanent establishment issues, assistance of the companies and their key individuals during the DRP, disputes at the level of French and European court of the validity of the procedures.

1-3, Villa Emile Bergerat

92522 Neuilly-sur-Seine Cedex

France

Tel: +33 1 47 38 42 19

Email: bruno.gibert@cms-bfl.com

Website: www.cms-bfl.com

Bruno Gibert joined CMS Bureau Francis Lefebvre as an equity partner in 2001. He specialises in international taxation, with a particular focus on transfer pricing matters. In this last domain, he heads the transfer pricing group the CMS network has put in place within the tax practice.

He has 16 years' experience in 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 co-chairman of the OECD's forum on harmful tax practices between 1996 and 2001 and has been chairman of the EU joint forum on transfer pricing (EU JTPF) since 2002. He 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 chairman of the tax committee of the Club des Juristes.

Bruno is the author of a 2004 report to the French government on tax security in France 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 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.

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

He is fluent in French and English.

181 avenue Charles de Gaulle

92524 Neuilly sur Seine Cedex

France

Tel: +33 01 55 61 48 31; +33 01 40 88 22 50

Fax: +33 01 55 61 21 43

Email: rgrau@taj.fr

Website: www.taj.fr

Romain Grau is a partner with the French tax controversy team of Taj, an international law firm and part of the global Deloitte member firm network.

Since 2008, Romain has also served as vice president of a local assembly, giving him an in-depth understanding of French tax laws which he uses when advising clients.

Romain served from 2004 to 2007 as a judge for the French Administrative Court dealing with tax law in the territorial jurisdiction of Versailles, the French business centre of La Défense.

Experience gained in this role has given Romain insight into the processes and policies of the French tax authorities, which he applies in his role as client adviser.

Throughout his career, Romain has represented clients in matters in all stages of litigation proceedings and has assisted many companies to litigate tax issues heard by the French tax authorities and the courts.

Romain was a lecturer in tax law at the IEP of Paris (Sciences Po Paris) from 2005 to 2010. He has written many articles for specialised tax publications including the Revue de Droit Fiscal and Taj's blog 'Fiscalité et Stratégie' discussing tax controversy matters. Romain is a graduate of the Institute of Political Studies of Paris – Public Policy Department, and from the French National School of Administration (ENA).

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 Taj's 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 Anderson in 1999. Following that role he joined Taj, where he now focuses his practice on counseling French and foreign firms, 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.

5 Boulevard Malesherbes

Paris, 75008

France

Direct line: +33 1 42 68 47 85

Email: sandra.hazan@dentons.com

Website: www.dentons.com

Sandra Hazan, a partner at the Paris office, is the head of the Dentons Europe tax group and co-head of the Dentons global tax group. Sandra has a highly successful track record – going back more than two decades – of solving complex tax issues facing clients across all geographies, with a special focus on tax audits, tax litigation and all types of disputes with tax authorities.

As an expert in French and international tax law, Sandra is especially highly acclaimed in international tax restructuring and planning, and transfer pricing. 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.

Sandra regularly publishes articles on tax innovations in professional periodicals and the business press (Cyberdroit, Company Law Handbook France). She is an active participant in various tax conferences in France and worldwide (EFE, CESCTI, IBA, IFA). Sandra is a founding member of Club du Luxe and actively participates in various successful initiatives aimed at women in business (French Women Tax Experts Association and Cosmetic Executive Women). Sandra has been recognised as a leading tax practitioner in France in prominent legal and other professional directories including, most recently, International Tax Review and Chambers and Partners.

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 and 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 numerous advance pricing agreements, competent authority procedures, audit defense 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 on 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 a member of the Scientific Committee of the Financial Directors, Management Control's French national association Directeurs Financiers et de Contrôle de Gestion (DFCG), and the International Fiscal Association (IFA). He was named a member of the 2008 government commission on tax safety, a co-founder of the Deloitte global transfer pricing team, and a member of the Tax Committee of the International Chamber of Commerce. 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.

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, the Deloitte law firm in France. 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 specializes in e-invoicing advisory work as well as tax audits and computerised tax audits 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 the French National Tax School (Ecole Nationale des Impôts) and has been a fully qualified certified information system auditor (CISA) since 1992.

181 avenue Charles de Gaulle

F-92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 40 88 83 81

Fax: +33 1 55 61 54 04

Email: jtrucchi@taj.fr

Website: www.taj.fr

Jean-Luc Trucchi joined Taj in 2001, and has been involved with transfer pricing issues for more than 30 years. He founded and directed for five years the division of the French tax administration specialised in international tax audits and in transfer pricing. A graduate from the National Tax School (Ecole Nationale des Impôts (ENI)), Jean-Luc had a previous experience of 20 years of accounting audit acquired in different economic sectors before joining Taj. He also runs numerous training seminars on the subject of transfer pricing.

With his track record, Jean-Luc has developed within the law firm Taj, where he heads the transfer pricing team, a unique expertise in international tax optimisation, in transfer pricing documentation and in assistance provided to companies regarding the management of their tax audits on national territory.

Jean-Luc is responsible for the overall client engagement, and oversees each project to ensure that clients' quality requirements are met.