Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Baker Mckenzie France has more than 40 tax professionals working in France and has more than 950 tax practitioners globally. Caroline Silberztein leads the French transfer pricing team. 

The team has comprehensive experience in negotiating with the French competent authority. Baker Mckenzie has reached numerous APAs and MAPsfor various clients.


The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.


LPA-CGR merged with CGR Legal (a leading energy and corporate law boutique firm) and has more than 180 specialised lawyers. LPA-CGR has 10 offices worldwide with a strong presence in Asia, including three offices located in Shanghai, Hong Kong and Tokyo. Partner Sandra Fernandes heads the tax department, and Fanny N’Guyen leads the transfer pricing practice and heads the Chinese office.

N’Guyen has advised numerous clients in tax audit and preparing transfer pricing documentation, some in foreign jurisdiction such as Asia.

Sullivan & Cromwell

Sullivan & Cromwell’s French tax team specialises in transactional tax and litigation services, and is active in the areas of M&A and capital markets. The firm offers clients its expertise in the cross-border area. It usually advises large companies listed on the CAC40 on strategic tax concerns such as the interpretation of new legislative and regulatory changes. Tax litigation is increasingly a major part of its advisory, accounting for 50% of its work.

Sullivan & Cromwell is currently advising a large manufacturer in the automotive industry with respect to transfer pricing.


Grégoire de Vogüé, partner, leads Taj’s transfer pricing team, and it offers full transfer pricing services such as documentation, dispute resolution, examination defence and MAP, transfer pricing policy set-up and financial services. The firm was involved in the committee-led discussions on requirements for transfer pricing documentation implemented in France, from which the team gained specific knowledge on what to include in transfer pricing documentation.

The firm has developed digital tools to assist its clients to better determine transfer pricing exposure, facilitate managing its day-to-day operational transfer pricing and build a reliable documentation pattern worldwide, providing the ability to guide and monitor transfer pricing from the centre. 

One client was at risk from new entrant competitors and needed to set up third party policy that would resist the new entrants’ aggressive pricing policy. 

De Vogüé advised a European industrial company by running a BEPS risk assessment, and identified hefty potential exposure between France and another jurisdiction. The solution involved determining an applicable transfer pricing model and setting up a strategy to implement the new model –encompassing legal, tax and operational maters – securing the restructured transfer pricing policy through a bilateral APA and readying the negotiation with the unions on the future profit-sharing impact of the new transfer pricing model.

Taj has bolstered its tax practice with the hiring of five partners from the likes of PwC and European Commission: Donato Raponi, Thierry Morgant, Alice de Massiac, Marine Gadonnieux and Julie Reynier.