Sullivan & Cromwell's French Tax Group has extensive experience advising major French corporations and North American companies with interests in France. The Firm advises on all manner of tax issues, providing sophisticated advice for businesses doing work in the region.
 
The Firm's French tax lawyers blend an international perspective with peerless knowledge of French tax law. The Group has expertise in:
  • mergers and acquisitions,
  • tax audits and controversy,
  • capital markets, and
  • restructuring.
     
In addition to specialized work on tax matters, the Paris office also serves the needs of the Firm's regular corporate clients on a wide range of issues.
 

SELECTED REPRESENTATIONS

Sullivan & Cromwell’s French Tax Practice has been engaged in a wide range of matters and has globally oriented expertise in French tax matters. Some highlights of the work undertaken by the team include representations of:
 
  • Air Liquide on tax matters related to its acquisition of Airgas for €12 billion
  • Altran on tax matters relating to its €845 million acquisition of Aricent from a group of investors
  • EDF Invest on tax aspects of its acquisition, together with Atlantia and Aeroporti di Roma, of a 60% stake in the French airport of Nice Cote d’Azur, from the French State
  • EDF on tax aspects of its sale of 49.9% of the shares in Réseau de Transport d’Electricité (RTE), the company operating the French high-voltage power grid, to Caisse des Dépôts and CNP Assurances on the basis of a value of €8.2 billion for 100% of RTE’s equity
  • Elis on tax aspects of its acquisition of 100% of the share capital of Berendsen, a U.K. listed company, for €2.46 billion
  • Eurazeo on tax aspects of the sale of 6% of the share capital of Moncler, at a price exceeding €200 million
  • Eutelsat on tax matters relating to the $500 million joint venture with Viasat
  • Pathé on tax aspects of its buyout from Gaumont of the Cinémas Gaumont Pathé shares
  • Rhône Capital on tax aspects of its 100% share capital acquisition of Zodiac Pool, for approximately $1.2 billion
  • AFEP on a litigation before the French Constitutional Court regarding the conformity to the Constitution of certain tax rules
  • Air Liquide on a tax dispute between Air Liquide and The French State
  • BPCE on tax litigation regarding the application of the 3% contribution on dividends, in respect of buy-back of shares
  • A group of CAC 40 companies (including Total, Sanofi, LVMH, Danone, Vivendi and others) & AFEP on a joint litigation before the European Court of Justice and French Constitutional Court regarding the 3% tax ruling on dividends – the amount at stake for our clients exceeded €2 billion
  • Crédit Agricole on a tax litigation case related to the recapitalisation and sale of its Greek subsidiary (Emporiki) – the amount at stake exceeds €1 billion
  • Fiat Chrysler Automobiles, in relation to tax rulings in Luxembourg, which have been declared unlawful state aid by the EU Commission
  • Natixis on its landmark win against the tax authorities
  • Orange (previously France Telecom) on a major tax litigation case
  • Vivendi on tax litigation regarding the application of a specific worldwide tax regime, obtained via a tax ruling