France

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 partner in the Paris tax department and heads the Paris private investment funds group. Sabina has a wide-ranging tax practice with a strong emphasis on complex tax structuring of international transactions, often involving multi-sponsors leverage buy-outs. She also regularly advises corporate clients on their taxation issues in connection with tax restructurings and/or refinancings. Some of her recent experiences include the Numéricable – Completel transaction for Cinven and Altice; and the Zodiac transaction for the Carlyle Group.

More specifically, as a member of the firm's private investment fund group, she specialises in the structuring of private investment funds with a particular focus on private equity funds and mezzanine/preferred equity funds. Her tax expertise coupled with her funds expertise has allowed Sabina to advise on innovative funds structures. Her recent experiences include advising LBO France on the setting up of the first French regulated and leveraged investment vehicle for the purchase of discounted debt; and advising 17 Capital on the setting up of the first dedicated provider of mezzanine and preferred equity financing for private equity portfolios.

Financial institutions rely on Sabina's tax guidance regarding securitisations, and she has also advised leading investment banks on public offers of shares and both offers and issues of other types of financial instruments (such as collateral debt obligations and repo structures).

Sabina joined Mayer Brown in 2007 after nine years of practice with two UK magic circle firms (having worked in their London and NY offices for more than four years and in their Paris office for five years). She is fluent in French and English as well as in her native Italian.

181 avenue Charles de Gaulle

92524 Neuilly sur Seine Cedex

France

Tel: +33 (0) 1 55 61 48 31; +33 (0) 1 40 88 22 50

Fax: +33 (0) 1 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 utilises 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 at all stages of litigation proceedings and has assisted many companies with litigating 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 specialist 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 the Taj indirect tax and 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 counselling French and foreign firms, advising some of the firm's largest clients.

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

181 avenue Charles de Gaulle

F-92524 Neuilly-sur-Seine Cedex

France

Tel: +33 1 5561 6346

Fax: +33 1 5561 6104

Email: gmonsellato@taj.fr

Website: www.taj.fr

Gianmarco Monsellato is a registered attorney, CEO of Taj in France – an international law firm and part of the global Deloitte member firm network – and global managing director – Tax Clients, Markets and Industries, Deloitte Touche Tohmatsu.

His experience covers a wide range of industries and he advises and defends leading European, Chinese, Japanese, Korean and US multinational companies on their international tax and transfer pricing policies.

Gianmarco has more than 20 years of tax experience and created the French transfer pricing group. He has led numerous advance pricing agreements, 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 re-engineering projects, including many supply chain management and intangible planning engagements. He serves as strategic tax adviser to CFOs and tax vice presidents of leading companies. And 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. He is joint author of Cahier du Cercle des Economistes: Tax strategy of the States and the Companies: sovereignty and competition, and author of a strategic note of the Choiseul Institut: Towards a new fiscal Contract.

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 40 8883 81

Fax: +33 1 55 61 54 04

Email: jtrucchi@taj.fr

Website: www.taj.fr

Jean-Luc Trucchi is an attorney-at-law and a specialist of the transfer pricing team of Taj, an international law firm and part of the global Deloitte member firm network.

His previous experience with the French tax authorities has afforded him in-depth knowledge of transfer pricing matters. He has also been involved in competent authority negotiations on the French tax authority side.

Jean-Luc brings the French tax authority's audit sensitivity to the transfer pricing team which allows it to fine tune its approach for potential challenges from the tax authorities. He has been involved in tax audits, transfer pricing projects, advance pricing agreements, and mutual agreement procedures. His expertise also encompasses dispute resolution, litigation, and cross-border controversy matters across a wide range of industries.

Jean-Luc was head of the 30th Brigade of the French Tax Administration's DVNI (Direction des Vérifications Nationales et Internationales), in charge of tax audits of large multinational companies, from 1995 to 2001. Previously, Jean-Luc spent more than 15 years as a tax inspector and adviser within the French Tax Administration. He was also a tax inspector with the National Tax School in France.

Jean-Luc holds a master's degree in law from the University of Nice, France.