Gauthier Blanluet

Mergers & Acquisitions and Other Corporate Transactions

• Icade and Icade Santé on tax matters in the sale of Icade’s stake in Icade Santé and the sale of Icade Healthcare Europe’s asset portfolio, for an estimated total value of €2.6 billion
• Suez in connection with the acquisition by Veolia, on the carve-out of the “New Suez” (representing revenues of c. €7 billion) and its sale to a consortium of investors
• Pershing Square on tax matters related to its $4 billion acquisition of a 10% share in Universal Music Group from Vivendi
• Fiat Chrysler Automobiles N.V. on tax matters related to its $60 billion 50/50 merger with Peugeot, creating the new company, Stellantis N.V.

• EXOR Nederland N.V. in connection with Covéa Coopérations S.A.’s $9 billion proposed purchase of PartnerRe Ltd from EXOR
• EssilorLuxottica S.A. in its €5.5 billion acquisition of a 76.72% interest in GrandVision N.V. from HAL Optical Investments B.V.
• Altran on tax matters related to its $2.0 billion acquisition of Aricent from a group of investors led by KKR
• Unibail-Rodamco on French tax and structuring aspects of its €21.7 billion acquisition of the Westfield Group

Tax Controversy

• Crédit Agricole in a multibillion tax litigation case before the Supreme court and the French Constitutional Court related to the recapitalisation and sale of its Greek subsidiary (Emporiki)
• Air Liquide in the context of the dispute between Air Liquide and The French State in order to obtain the refund of the French withholding tax (Précompte) for an amount in excess of €200 million
• Air Liquide on a landmark win before the Supreme Court relating to the imputation of tax credits on the 5% dividend taxation pursuant to the parent-subsidiary regime
• Vivendi on several litigations before the Supreme Court in connection with the worldwide tax consolidation regime
• Groupe BPCE in several confidential tax litigations, and on a landmark win before the French Supreme Court relating to the application of the 3% tax on dividend distributions to share-buybacks
• HSBC in various confidential tax litigations
• The State of Kuwait, in a litigation against the French State before the Supreme Court
• a group of the main CAC 40 companies (including Total, Sanofi, LVMH, Danone, Vivendi and others) and AFEP on a joint litigation before the French Court and Constitutional Court regarding the 3% contribution on dividends. S&C won before the Supreme Court and before the European Court of Justice
• Orange (previously known as France Télécom) on a major tax litigation case related to the treatment of reserves in the context of a merger
• a consortium composed of the AFEP (a non-profit association for Authorised Payment Institutions operating in the European Economic Area) and six French public companies (Total, Air Liquide, Veolia, Pernod Ricard, Lafarge and Technip), on a landmark Constitutional Court decision concerning the Non-Cooperative States Regime