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:

TRANSACTIONAL TAX

  • Adecco on tax matters related to its acquisition of 60% of the share capital of Akka Technologies
  • Air Liquide on tax matters related to its €12 billion acquisition of Airgas
  • Altran on tax matters related to its €845 million acquisition of Aricent from a group of investors
  • EDF Invest on tax matters of its acquisition, of a 60% stake in the French airport of Nice Cote d’Azur from the French State
  • Elis on tax matters of its €2.46 billion acquisition of 100% of the share capital of Berendsen, a U.K. listed company
  • Eurazeo on tax matters of the sale of 6% of the share capital of Moncler
  • Pershing Square, a special a special purpose acquisition company, on tax matters related to its $4 billion acquisition of Universal Music Group from Vivendi
  • Praxair on tax matters in relation to its $80 billion merger of equals with Linde
  • Stellantis formerly Fiat Chrysler Automobiles, on tax matters related to its $60 billion 50/50 merger with Peugeot
  • Suez on tax matters in connection with Veolia’s acquisition of Suez shares representing 29.9% of the capital of Suez from Engie and the subsequent agreement with a consortium of investors to create a new Suez resulting from the divestment of around €7.0 billion of assets
  • Tiffany & Co on tax matters related to its $16 billion acquisition by LVMH Moët Hennessy – Louis Vuitton

TAX LITIGATION

  • 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) and AFEP on a joint litigation before the European Court of Justice and French Constitutional Court regarding the 3% tax ruling on dividends
  • Crédit Agricole in a tax litigation case before the Supreme Court related to the recapitalisation and sale of its Greek subsidiary (Emporiki)
  • Fiat Chrysler 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) in a tax litigation case before the Supreme Court
  • Vivendi on tax litigation regarding the application of a specific worldwide tax regime, obtained via a tax ruling paris