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Annabelle Bailleul-Mirabaud

Partner

Contact
CMS Francis Lefebvre Avocats
2 rue Ancelle
92522 Neuilly-sur-Seine
Cedex
France
Languages French, English, Spanish, Italian

Annabelle Bailleul-Mirabaud specialises in international taxation with an expertise on permanent establishments, CFC and substance issues, assisting leading multinational groups in tax audits and litigation.

She also assists multinational groups on a day-to-day basis in relation to international taxation matters including transfer pricing and taxation of cross-border flows. Annabelle has a significant experience in the structuring and implementation of worldwide incentive plans.

She joined CMS Francis Lefebvre in 2003 after several months with CMS Francis Lefebvre, New York. She is one of the authors of Business Operations in France (Bloomberg BNA).

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Best Lawyer, Tax Law

Best Lawyers 2024

Relevant experience

  • Former lecturer in international taxation matters for post graduates at Panthéon Sorbonne University Paris I (2006-2007).
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Memberships & Roles

  • Member of Institut des Avocats Conseils Fiscaux (IACF)
  • Member of International Bar Association (IBA)
  • Member of International Fiscal Association (IFA)
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Publications

  • Recent updates on the French digital services tax (DST) – Revue de Fiscalité internationale / Editions JFA (07/12/2022)
  • The Conversant/Value Click Case in France: Substance-Over-Form Interpretation of Permanent Establishment – Tax Notes International (21/06/2021)
  • Piliers 1 et 2: la sécurité juridique nécessitera l'élimination efficace et homogène des cas de double imposition, co-auteur – Editions Francis Lefebvre (01/12/2022)
  • DAC 7 : le renforcement de la coopération fiscale pour les plateformes numériques, co-auteur – Option Finance (03/05/2021)
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Education

  • HEC Business School (2001)
  • Master of management – University Bocconi, Milano
  • Master of corporate and tax law - Paris XI-Sceaux (2001)
  • CAPA (2003)

 

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30/04/2019
Brexit : l’impact fiscal d’un « no deal » sur vos investissements
02/04/2019
Brexit : un «no deal» lourd de conséquences fiscales tant pour les sociétés...
28/03/2019
Hard Brexit : quelle fiscalité pour vos investissements ?

Feed

26/01/2024
CMS Expert Guide to Mastering OECD's Pillar Two in France
1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules? Yes. 2. What is the implementation status of Pillar Two/GloBE rules? The EU Minimum Taxation Directive was...
Comparable
30/10/2022
CMS - Meet our experts at The International Bar Association (IBA) Annual...
More than 70 percent of the world’s purchasing power is located outside of the United States. So for US companies, establishing or growing their business and investments with their main trade partners – whether in the UK, the European Union, China, Africa or the Middle East – is essential for their success. However, doing business in diverse markets, each with its unique legal environment and ways of practicing law, requires specialist knowledge. Our more than 5,000 lawyers worldwide provide business-focused advice, whether in a single market or across multiple jurisdictions. Our focus is on building long-term partnerships to keep our clients ahead in their chosen markets. CMS lawyers are pleased to be attending the International Bar Association (IBA) Annual Conference from 30th October to 04th November 2022. Below you can find an overview of our partners attending the IBA Annual Conference, representing a range of jurisdictions, practice areas and sector specialisms. To arrange a meeting, please contact melania. kozyra@cmslegal. com. CMS lawyers will be participating in the following panel dis­cus­sions:France based Partner Annabelle Bail­leul-Mira­baud will be chairing Roundtables discussions of global tax trends, Wednesday 2 November (1430 - 1730)France based Partner Frédéric Roux and Michel Collet will participate in Roundtables discussions of global tax trends, Wednesday 2 November (1430 - 1730)Italy based Partner Paolo Bonolis will participate in the panel on Contracting of IT assets (digitalisation 2.0) in an increasingly complex regulatory environment, Monday 31 October (1430 - 1545)Italy based Partner Laura Opilio will take part in 3 panels:chairing Addressing dis­tri­bu­tion-re­lated shortages of medicines and medical devices from a multi-jur­is­dic­tion­al perspective meeting, Tuesday 1 November (1615 - 1730);Hot topics in international commerce, trade, franchising and product law, Monday 31 October (0930 - 1230);and Best practices in supply chain in the post (or continuing) Covid environment, the war in Ukraine and the impact of digitization, Wednesday 2 November (1615 - 1730)Germany based Partner Bjoern Gaul and Orly Gerbi of Herzog Fox Neeman, Israel will moderate a panel on New developments on Al in the workplace on 02.11.2022 (Wednesday) 9.30 h – 10.45 a. mEmployment and Industrial Relations Law Committee (Lead for moderators and speak­ers)Tech­no­logy Law Committee (one speaker) with the attending experts below:Patricia Barboza, CGM Advogados, BrazilSteven T. Hunt, Technology & Work, SAP Innovation Office, USACliff Jurkiewicz, Vice President, Strategy at Phenom, USAInge de Laat, Rutgers & Posch, Neth­er­landsAnthony J. Oncidi, Proskauer, USAVikram Shroff, Nishith Desai, IndiaYardenne Assa, Co-Founder and CEO, Unboxable, IsraelTo find out more about CMS, visit the About CMS section. For further information, please see our partners attending the conference in the gallery below and an overview of all our expertise areas.
23/09/2020
Tax Connect Flash
On 15 July 2020, the European Commission adopted a new tax package to support economic recovery and long-term growth within the European Union (“EU”). Furthering EU tax policy, the package builds...
23/09/2020
DAC 7: online platforms, key players-to-be in the European tax transparency...
On 15 July 2020, the European Commission adopted a new tax package to support economic recovery and long-term growth within the European Union (“EU”). Furthering EU tax policy, the package builds...
04/03/2020
Tax Connect Flash
SummaryPillar OneUnified Approach: SummaryUnified Approach: Amount AAmount A: Scope Amount A: ThresholdsAmount A: Computation and Al­loc­a­tionUni­fied Approach: Amount B Unified Approach: Amount C Pillar...
24/07/2019
Tax Connect Flash
Pending the implementation of a coordinated international solution aiming at taxing major digital companies, the bill introducing a French digital services tax was definitively voted on 11 July 2019...
24/07/2019
Tax Connect Flash
Pending the implementation of a coordinated international solution aiming at taxing major digital companies, the bill introducing a French digital services tax was definitively voted on 11 July 2019...
24/07/2019
Tax Connect Flash
Pending the implementation of a coordinated international solution aiming at taxing major digital companies, the bill introducing a French digital services tax was definitively voted on 11 July 2019...
30/04/2019
Intellectual property taxation in France
12/03/2019
Taxation of the digital economy
This publication aims to identify various aspects of the digital economy and to consider whether income taxes are the most effective and efficient way to tax this economy. Do we need a revolution in the...
07/10/2018
IBA Annual Conference 2018
Several of our partners will be at the IBA Annual Meeting in Rome, Italy, representing a range of jurisdictions, practice areas and sector specialisms. To arrange a meeting during the IBA, please contact...
15/01/2018
CMS Francis Lefebvre Avocats coopts four new partners
CMS Francis Lefebvre Avocats announces the cooptation of four new partners: Annabelle Bail­leul-Mira­baud, Damien Decolasse, Ludovic Duguet and Thomas Laumière. Of the over 400 lawyers, now 112 are partners...