Pierre-Eric Coquard

Working on corporate restructuring projects involving holding entities (e.g., mergers, contributions, increase/decrease of share capital, domestic and cross-border) and financing structure of the Group (e.g., thin-capitalization, debt-equity financing arbitrage, intragroup financing structure). Working also on the tax aspects of corporate/business acquisitions performed at Group holdings level (due diligence, structuring, SPA advice and post-deal integration) : Rimowa, Christian Dior Couture, Tiffany, Wine&Spirits. Between February and Décember 2021, I coordinated the integration process of Tiffany's tax department for both functional (reporting/compliance/transfer pricing/corporate tax) and organizational aspects (tax operating model audit and recommendations). Other responsabilities at Group holding level : dividend taxation, tax audits, transfer pricing for intragroup financing, Corporate Investment vehicles taxation (209-OA CGI and FCPIs), VAT, free shares grant plans taxation, relations with external auditors, FATCA/CRS policy and compliance coordination. Working on tax aspects of investment vehicules : setting up of corporate investment structures and follow up of tax aspects in several acquisitions in France, Israel, UK and Switzerland. Daily Business partners : Group Holdings Accounting, Group Finance and Treasury, Group Consolidation, Group Legal and M&A Departments.

Manager in the Transaction Tax Services of EY. Providing of a wide range of tax services for domestic and cross-border transactions (small to large cap) i.e., acquisitions and disposals of shares or assets, financing/refinancing, restructurings or initial public offerings of companies, mainly for multinational corporate groups or private equity funds. Buy-side offering : structuring and post-deal integration (acquisition structure, tax treatment of deal costs, intra-group financing and business combinations), due diligence, modelling i.e. tax effects quantification and monitoring (tax cash flows), review of legal documentation ; Sell-side offering : exit readiness and vendor structuring (pre-disposal reorganizations), vendor due diligence, SPA advice.

Member of the French International Tax Desk of EY in New York City between December 2013 and June 2014. Tax advising for US corporate groups or PE houses in relation with their investments in France. The French EY Tax Desk proposes full range of services such as transaction tax services, tax assistance on financing or refinancing structure implementation, Effective Tax Rate (ETR) management or TESCM (Tax Effective Supply Chain Management) structures implementation and assistance on any other International tax plannings involving France.

Listed on NYSE Euronext Paris (LG / Turnover 2010 €15 Bn / CAC 40) Word leader in building materials, present in 78 countries Tax Competency Center / Group Finance Department Internship performed within the framework of the Paris Bar School: Tax analysis of cross border restructurings : Impact on ETR, review of SPA - Contribution agreements - Shareholders agreements, Tax & Legal structuring ; Assistance to tax audits ; Drafting of technical memos with respect to international tax and VAT issues for the BU Management (CEO - CFO - Regional Controllers - Legal counsels - Project managers).

Trainee Lawyer Corporate Tax Department - Drafting of technical memos re French & International tax issues (pricing of shares for Net Worth tax purposes, "démembrement de propriété" within the framework of real estate planning for an entrepreneur) ; - Drafting of parts of vendor due diligence reports (thin-cap, Fiscal unity, Charasse amendment,...);

Internship performed in Paris within the framework of the Master of Business Law: - Reseach and drafting of technical memos re French Tax issues - Data Room preparation - Tax advisor assistant re Corporate and Personal income Tax law: review of Corporate tax returns, implementation of tax efficient vehicles in Luxembourg

One year Internship in the framework of EDHEC Business School "Grande Ecole" Program Tax advisor: - Tax planning: structuring for holding / financing / cash reengineering activities through Luxembourg via tax effective vehicles. - Compliance i.e. drafting/filing income/Net wealth tax returns as well as computation of tax provisions. - Client profile: mainly US and UK groups or investment funds. Service Line: Tax International/Corporate Advice on tax issues relating to international corporate structures, reorganizations and financing arrangements, Intellectual Property planning, investment and acquisition structures and company migrations.

Company law - Capital markets - Tax law Thesis : « EU Regime of Tax State Aid »

Finance - Strategy - Marketing