Tirard Naudin A.A.R.P.I

The firm: Tirard, Naudin has been regarded as a leading law firm in the international/private client market for more than three decades. The firm was founded in 1989 by Maryse Naudin and Jean-Marc Tirard, later joined in 2011 by Ouri Belmin, who is now the firm's managing partner.

The firm specializes in international tax and estate planning for a wide variety of clients, mainly high net worth private clients and their families who need help in relation to complex estate planning and international structuring matters.

The firm is particularly renowned for its expertise in the legal and tax treatment of trusts, and more generally in matters involving conflicts between common law and civil law systems. The firm's partners also have a wealth of expertise in property tax issues and the creation of efficient structures for non-resident investors.

Most of the firm's clients are leading foreign law firms, or referred by leading foreign law firms, as well as foreign private banks, trust companies, family offices and fiduciary companies.

Tirard, Naudin has been involved in numerous tax litigations, in particular concerning European community freedoms and fundamental law principles, and the firm’s lawyers have an excellent knowledge of all stages and aspects of the French tax procedure.

Areas of practice: Tirard, Naudin advises individuals on all French aspects of international taxation and estate planning, including transfers of tax residence, legal and tax treatment of successions and liberalities and matters involving conflicts between common and civil law systems. In particular, the firm has a unique expertise in France in the trust field (both from a legal and an international tax standpoint) and in the context of cross-border inheritances.

The firm’s lawyers are very experienced in setting up and structuring multinational large and medium sized groups establishing in Europe and have a proven expertise in comparative corporate taxation of trading and holding companies within the EU (Maryse Naudin and Jean-Marc Tirard negotiated the first France-US transfer pricing APAs for Visteon Corporation, an American global automotive electronics supplier spun off from the Ford Motor Company in 2000).

Tirard, Naudin also has a considerable experience in advising foreign investors acquiring real property in France. Ms Naudin is a frequent speaker at seminars dealing with these issues.

Finally, the firm has been involved in numerous tax litigations:

• • Before French Courts, in particular in matters involving European community freedoms and fundamental law principles (Constitutional and Conventional);

• • Before the European Commission (obtaining decision against the French government);

• • In the context of the “Mutual agreement Procedure” provided by Article 25 of the OECD Model tax convention, in order to activate negotiations between States.