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:
 
  • a group of counterparties holding financial guarantee insurance policies and other instruments issued by CIFG, in negotiating a plan to restore the financial position of the CIFG group, including related French aspects involving CIFG (Europe).
     
  • Amgen, in its acquisition of BioVex Group. S&C advised on U.S. and U.K. tax aspects of the transaction and provided input on certain French tax matters.

    This transaction was particularly challenging, given the complex terms and structure of the acquisition as well as the elaborate capital structure of BioVex Group and its subsidiaries.
     
  • AXA, on the tax aspects of AXA Global P&C’s securitization program and catastrophe bond offering.
     
  • BNPP, on several structured transactions.
     
  • Casino, on tax aspects in an arbitration case.
     
  • Crédit Agricole, on the tax aspects of the €6.6 billion merger of Crédit Agricole’s and Société Générale’s asset management businesses (now known as Amundi Asset Management).

    This transaction required a complex tax ruling obtained from the French tax authorities.
     
  • Crédit Mutuel, on certain tax aspects related to a joint venture in the consumer credit business.
     
  • Electricité de France, on the tax aspects of its $2.1 billion tender offer for all outstanding shares of EDF Energies Nouvelles (France) that it did not currently own.
     
  • Eutelsat, on certain tax aspects related to its organization.
     
  • France Telecom, on several tax litigation matters.
     
  • Goldman Sachs,  in connection with the restructuring and financing of Eurotunnel.
     
  • Morgan Stanley, on a derivative product.
     
  • Natixis, in connection with the €35 billion guarantee issued by BPCE, its parent company, to cover toxic assets held by Natixis.
     
  • Polygon Investments, on the tax aspects of a financial transaction.
     
  • Rio Tinto, in the divestment of its Alcan Global Packaging business in three separate transactions comprising: the $2.03 billion sale of the Global Pharmaceuticals, Global Tobacco, Food Europe and Food Asia businesses to Amcor; the $1.2 billion sale of the Food Americas packaging business to Bemis; and the sale of Alcan Beauty Packaging to Sun Capital Partners. The tax aspects of these transactions included multiple cross-border issues and required the involvement of the Firm’s U.S., U.K. and French tax practices.
     
  • Suez Environnement, on the tax aspects of its spin-off.
     
  • Technicolor, on the tax aspects of its debt restructuring and on several tax litigation matters.
     
  • Total, on the tax aspects of several debt offerings.
     
  • the underwriters, on the tax aspects of the IPO of CFAO.
     
  • Whitehall, on several tax litigation matters.