French Tax

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