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Stéphane Gelin

Head of the CMS Tax Group

CMS Francis Lefebvre Avocats
2 rue Ancelle
92522 Neuilly-sur-Seine
Languages French, English

Stéphane Gelin is Head of the CMS Tax Group. In this position, he leads an international team of 400 tax lawyers.

Stéphane specialises in international taxation and transfer pricing. He has advised French and international multinational corporations in this field for nearly thirty years. He has participated in several major projects involving the structuring of global transfer pricing, operational restructuring and the documentation of French and foreign transfer pricing. He offers his clients assistance in French and international tax litigation (specifically competent authority procedures, arbitration procedures and advance pricing agreements). He also advises clients on international financing matters, cross-border restructuring, joint ventures and acquisitions.

Stéphane joined the International Taxation Department of CMS Francis Lefebvre Avocats in June 2003 as a partner, having spent sixteen years at Ernst & Young in Paris, where he was the partner responsible for the transfer pricing business, and in New York where he was responsible for the French tax desk.

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Legal 500 EMEA 2019

Tax (Europe-wide)

Chambers Europe 2018

Relevant experience

  • HSD Ernst & Young (1987-2003)
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  • Graduate of the Economics and Finance Department, Institute of Political Studies (IEP), Paris (1986)
  • Master's degree in Business Law and Taxation, University of Paris V - René-Descartes (1983)
  • Post-graduate degree (DESS) in Business Law and Taxation, specialising in Applied Taxation, University of Paris V - René-Descartes (1985)
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  • Member of the Council of the Chartered Institute of Taxation
  • Member of IFA (International Fiscal Association)
  • Member of ACE (French Association of Corporate Legal Advisors)
  • Member of IACF (French Institute of Tax Lawyers)
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  • Dossier Pratique "Prix de transfert", co-author - Editions Francis Lefebvre (October 2016)
  • Prix de transfert : la méthode du partage des bénéfices, meilleure et seule méthode ? - Revue de Droit Fiscal (24/07/2014)
  • Transfer Pricing Manual, co-author, BNA International (september 2008) Les prix de transfert, co-author, Editions Francis Lefebvre (june 2008)
  • Articles in such publications as Tax Planning International Review, Tax Notes International, Internation Tax Review, Les Echos and Option Finance
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Show only
July 2020
Trans­fer pri­cing and the Cov­id-19 eco­nom­ic down­turn
06 October 2016
The New Per­man­ent Es­tab­lish­ment Status After BEPS: Déjà Vu In France?
The fi­nal re­port on Ac­tion 7 of the BEPS ini­ti­at­ive (Pre­vent­ing the ar­ti­fi­cial avoid­ance of Per­man­ent Es­tab­lish­ment Status – OECD – Oc­to­ber 2015) pro­poses to amend sig­ni­fic­antly Art­icle 5 of the OECD...
March 2020
CMS Tax Glob­al Bro­chure
25 June 2019
Are Eth­ics Really what the Doc­tor Ordered to Cure Ag­gress­ive Tax Plan­ning?
Stéphane Gelin and Rose­mary Bil­lard-Moalic of CMS Fran­cis Le­fe­b­vre Avocats look at the ques­tions around the mor­al­ity and eth­ics of cor­por­ate tax plan­ning which now con­front tax ad­visers.
18 June 2019
An­nu­al Re­view 2018 – 2019
Cross­ing bor­ders is both the theme of this year’s CMS An­nu­al Re­view and a guid­ing idea that we had when we es­tab­lished CMS 20 years ago. At that time, we de­cided to cre­ate a high-qual­ity, ex­pert and mul­tijur­is­dic­tion­al law firm. This Re­view shows what we’ve achieved over the last year in pur­suit of this goal.Since 1999, work­ing across bor­ders has be­come a daily task for all our law­yers. We are one of the most in­ter­na­tion­al law firms, with more than 70 of­fices in over 40 coun­tries. Our 4,800 leg­al ex­perts world­wide work as one team across jur­is­dic­tions, prac­tice areas and sec­tors to en­sure that you get clear, ac­tion­able and busi­ness-fo­cused ad­vice. You can read about our mul­tijur­is­dic­tion­al sup­port for cli­ents in the stor­ies through­out this An­nu­al Re­view. For ex­ample: an in­ter­na­tion­al CMS team ad­vised Ad­vance / Ne­w­house Part­ner­ship on its pur­chase of Stage En­ter­tain­ment, one of the world’s largest theatre pro­du­cers and own­ers. Our law­yers spe­cial­ising in cor­por­ate, me­dia, real es­tate, tax, em­ploy­ment, IP, com­pet­i­tion and bank­ing all worked on the trans­ac­tion.Glob­al­isa­tion con­tin­ues to im­pact the busi­ness en­vir­on­ment pro­foundly, as do the key is­sues on the glob­al agenda such as the US trade talks with China, Brexit and the con­sequences of cli­mate change. With our glob­al firm struc­ture and mind­set, we help you an­ti­cip­ate the prob­lems you face in your daily op­er­a­tions. On page 28, you can read what some of our part­ners around the world have told us about the chal­lenges their cli­ents are cur­rently fa­cing.An­oth­er ma­jor factor shap­ing our daily work is the im­pact of tech­no­logy on all busi­nesses. This year, our an­nu­al event in Da­v­os on the oc­ca­sion of the World Eco­nom­ic For­um (see page 18) fo­cused on how in­creased di­git­al­isa­tion is af­fect­ing con­ven­tion­al busi­ness mod­els.Today, in­tro­du­cing more ad­vanced tech­no­lo­gic­al tools in­to leg­al prac­tice is a must in or­der to meet cli­ents’ qual­ity and ef­fi­ciency ex­pect­a­tions. For CMS, it is about more than just us­ing ar­ti­fi­cial in­tel­li­gence soft­ware or di­git­al tools. To us, in­nov­a­tion means de­vel­op­ing tech­no­logy to of­fer our cli­ents new high-qual­ity ser­vices and to provide new ways of de­liv­er­ing all our leg­al of­fer­ings. Our scale and pres­ence across many jur­is­dic­tions, coupled with our deep un­der­stand­ing of cli­ent needs in their loc­a­tions, means that we are very well qual­i­fied to de­vise such solu­tions. On page 16, some of our key in­nov­at­ors de­scribe the ways in which our tech­no­logy is be­ne­fit­ting cli­ents.I hope you find some in­ter­est­ing and thought-pro­vok­ing stor­ies in this year’s An­nu­al Re­view and wish you an en­joy­able read. My col­leagues in the CMS ex­ec­ut­ive team and I are al­ways happy to hear from you if you have any com­ments or ques­tions.Cor­neli­us Brandi, Ex­ec­ut­ive Chair­man
09 May 2017
Busi­ness Im­plic­a­tions of Brexit
A CMS Tax Ana­lys­is
06 December 2016
Busi­ness Im­plic­a­tions of BEPS
A CMS Tax Ana­lys­is
18 March 2015
BEPS – First steps in the im­ple­ment­a­tion of the Coun­try-by-Coun­try re­port­ing...
26 May 2010
Tax Con­nect Flash | France: Com­mis­sion­aires as Per­man­ent Es­tab­lish­ments?...