France

Partner

Mayer Brown

Paris

+33 1 53 53 43 43

lborey@mayerbrown.com

www.mayerbrown.com

Languages: French, English, Spanish

Bar admissions: Paris

Laurent Borey is one of France's leading tax lawyers on private equity matters (fund structuring and transaction) representing private equity sponsors.

He is singled out for his vast experience in the tax structuring of large, complex, cross-border M&A transactions and expertise in personal tax matters of top managers, tax audit and litigations.

• Advised the investment fund Charterhouse in the structuring of the acquisition of the insurance broker SIACI Saint Honoré

• Advised the French Dutch laboratory Cooper-Vemedia on the structuring aspects of the € 158 million acquisition of 12 pharmaceuticals brands from Sanofi

• Advised Altice NV on tax and structuring aspects of the IPO and NYSE Listing of Altice USA

• Advised Eurazeo with regards to the tax structuring of its acquisition from Accor of 85 hotels in France and Europe

Restructuring, M&A, Corporate taxes, Audit defence, Tax consulting, Transfer pricing

Consumer goods and services, Energy, Financial services, Food and beverage, Healthcare, Industrials, Investment management, Media, Pharma and life sciences, Real estate, Tech and telecoms

Association des Anciens d'Arthur Andersen

Université de Dijon: DESS de Fiscalité

Université Paris II Panthéon-Assas: Maîtrise Droit des Affaires et Fiscalité

Partner

CMS Francis Lefebvre Avocats

Neuilly-sur-Seine

+33 1 47 38 40 25

richard.foissac@cms-fl.com

cms.law/fr/FRA/

Languages: French, English

Bar admissions: 12th October 1990

Richard joined CMS Francis Lefebvre Avocats in 1988 and was co-opted as an equity partner in 1998. He chaired the firm's advisory board from 2009 to 2012. He is an expert in direct taxes, and mainly manages mainly cases 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; and tax systems for semi-public companies and local authorities.

Richard is also specialised in tax litigation and in tax penal claims. In this context, he and his team have spent many years assisting several groups, companies and their key individuals, in tax dawn raid procedures (section L 16B of the French tax code) and in tax criminal procedures; as a tax litigation lawyer, he also regularly pleads (including in criminal tax).

Richard is well known by the French tax administration as an expert of those matters, and regularly publishes different articles on these matters in specialised publications.

He is a lecturer at the Universities of Paris I (Panthéon-Sorbonne), Sophia-Antipolis and Montpellier. He is also a member of the IACF and of the ACE.

Direct taxes; corporation tax for listed and non-listed companies; personal income tax; real estate and finance taxation; tax litigation; tax penal claims.

Richard is a member of the IACF and of the ACE.

Postgraduate degree in business law from the University of Montpellier (DJCE)

Partner

Mayer Brown

Paris

+33(0)153534343

bhomo@mayerbrown.com

www.mayerbrown.com/people/benjamin-homo/

Languages: French, English

Bar admissions: Paris, France

Benjamin Homo has extensive experience representing taxpayers at all stages of tax disputes, from the assistance during the audit process to final litigation in front of French administrative and civil courts, including intermediary administrative phases and settlement negotiations.

• Assistance to a subsidiary of a French listed company against the re-characterization of debt into equity (300m euro reassessment, eventually fully waived by the authorities)

• Assistance to various French management teams in respect of the re-characterization into employment income of the gains derived from their equity investment in LBO Transactions ("Management Packages")

Transactions, Corporate taxes, Audit defence, Litigation, Tax consulting

Consumer goods and services, Financial services, Healthcare, Investment management, Real estate

• HEC Business School – Master in Management – Grande Ecole Degree – 1996

• Université Paris II Panthéon-Assas – Diplôme d'Etudes Supérieures Spécialisées (DESS) in International Tax – 1996

• Paris Bar – 1999

Partner

Mayer Brown

Paris

+33 (0)1 53 53 51 84

clalloz@mayerbrown.com

www.mayerbrown.com

Languages: French, English

Bar admissions: Paris

Building on extensive experience gained on successful tax audits and litigations for a wide range of French and foreign clients, Christopher focuses his activity on structuring organizations, transactions and investment schemes with measured risk-taking and defending his clients' positions before the French tax authorities or the French courts.

• Tax audit of a large multinational distribution group re an internal reorganization. Initial tax reassessment: c. €250 million. Final tax reassessment (after two years of negotiation): c. €15 million

• Tax audit of a wealthy entrepreneur re the sale of his group. Initial tax reassessment: circa €6 million. Reassessment eventually waived by the authorities

• Tax audit of a listed French company by a foreign administration (Middle East) re: transfer pricing

Corporate taxes, Audit support, Litigation, Tax consulting, International tax advisory

Consumer goods and services, Industrials, Investment management

1999: Certificate of specialisation in tax (with honours), University of Montpellier I.

1999: DESS – DJCE (specialized corporate and tax counsel qualification (with honours), post-graduate Degree in corporate and tax law (DESS), University of Nancy II.

2001: ICN Business School (with honours), University of Nancy II.

2002: Admitted to the French Bar.

Lawyer – Partner

Frenkel&Associés

Paris

+33 (0)1 42258888

a.frenkel@taxlex.com

www.frenkel-associes.fr

Languages: French, English

Alain Frenkel specialises in tax litigation, a field in which he has over 30 years of experience and is considered as one of the best. After having co-founded the law firm Veil Jourde, he created Frenkel&Associés in 2003. His partner Marc Pelletier is a leading specialist in constitutional law. They lead the main French tax litigation conferences.

• Layher, Constitutional Court, 2016: declaration of unconstitutionality of the provisions limiting exemption from the 3% additional corporate tax contribution on dividends to fiscally consolidated groups.

• The Firm also assisted Jeff de Bruges in claiming that the contribution was unconstitutional given the reverse discrimination introduced.

• Layher, Conseil d'Etat, 2017: annulation of the postponement of the repeal of these provisions until 01.01.2017 in the light of arguments based on the ECHR.

Pre-litigation, Litigation, Tax consulting, International tax advisory, Lobbying

Alain Frenkel is a member of International Fiscal Association (IFA) and Vice-President of IACF (Institut des avocats conseils fiscaux – Institute of Tax Lawyers).

Alain Frenkel has Masters in public and private law, a Ph.D. in law, is a Laureate of the Paris II University, and is also a graduate of Sciences-Po Paris.