Tax Advisers - Deloitte

France
Pierre-Jean Douvier
CMS Bureau Francis Lefebvre
1/3 Villa Emile-Bergerat
92522 Neuilly-sur-Seine
Paris
France
Tel: (33) 1 47 38 56 76
Fax: (33) 1 47 45 86 75
Email: pierre-jean.douvier@cms-bfl.com
Website: www.cms-bfl.com
Pierre-Jean Douvier joined the international taxation department of CMS Bureau Francis
Lefebvre in 1986 where he was co-opted as an equity partner in 1991. He formerly had
been with Coopers & Lybrand (1981 to 1984) and Ernst & Whinney (1984 to 1986). He
is specialized in transfer pricing, having 24 years’ experience in the area. The support of
a team of four economists within the firm is a major plus to assist clients in transfer
pricing. His other practice areas are cross-border transactions – including M&A,
financing, refinancing, hybrid financing and restructuring, financial leasing, European
and international taxation. He is a lecturer in international taxation at University of Paris
II-Assas. He is the author of several publications, including International taxation: 20 case
studies (LITEC), Tax law in international relationships (PEDONE), The regime of permanent
establishment (IBFD Amsterdam 2005), The regime of groups (Ed F Lefebvre, co-author,
2005/2006), Treasury management (Ed F Lefebvre, 2002) and The regime of partnerships
(IBFD Amsterdam 2005). He is an active member of the Institute for Tax Advisors
(IACF), of the International Fiscal Association (IFA), of the International Bar Association
(IBA) and is the honorary vice-president of the Trusts Committee of the IBA. He is a
member of STEP France. He is fluent in English and speaks German.
Pierre-Jean’s recent experience includes:
• assisting French and international key-pharmaceuticals groups (international
reorganizations, re-engineering of services, APA, transfer of functions);
• assisting international distribution and manufacturing groups (transfer pricing);
• assisting in transfer pricing litigations: domestic, competent authorities process and
European convention;
• review of transfer pricing methodologies to reduce risks in the event of future tax
audits (preparation of key elements with the assistance of economists within Francis
Lefebvre);
• assistance in global trading with respect to transfer pricing;
• assistance in M&A transactions, thin-cap rules connected to such M&A, followed by
revisiting transfer pricing methodologies;
• tax advice with respect to permanent establishment and the corresponding practicality
to reduce or eliminate such tax risks;
• transfer pricing and e-commerce: tax issues with respect to permanent establishment;
• withholding tax aspects of the various cross-border flows (fees, software content,
licensing of intangibles): domestic regime, income tax treaty aspects, EU law;
• transfer pricing/allocation of taxable income and expenses;
• issues with respect to effective seat of management of companies; and
• localization of companies/assets/functions depending on the activities involved.
78 Guide to the World’s Leading Tax Advisers