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EATON
- Tax Manager South Europe & Africa
montbonnot saint martin
2013 - maintenant
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Heineken France
- Responsable fiscal
Rueil-Malmaison
2009 - 2013
Tax Manager for the brewery and wholesale activities
26 tax consolidated companies, 2 b€ of consolidated turnover
Report to the Finance Director
• Management of tax, social and customs audits
Dealing with a computerized reconstruction of profits procedure, reassessment totally cancelled in 2010
Income tax and VAT audits on various subsidiaries
Frequent Custom’s audits in relation with excise duties on alcohol
• Proposition & management of the simplification of the organization chart of the group via mergers/winding-up
10 mergers achieved in FY 2010, 3 in 2011
• Monitoring and reporting of Effective Tax Rate, and deferred taxes according within IFRS 12
Monthly reporting of consolidated current and deferred tax, in order to calculate the income tax expenses, ensuring a reliable forecast of tax expenses of the group
• Management and assistance to the Accounting teams for tax compliance
Annual individual and tax consolidation returns, monthly VAT returns, custom’s monthly returns, local and other taxes
• Drafting of tax-related best practice procedures (SOX regulations) in coordination with the Netherland’s headquarters
• Tax planning
Double dip resulting from the disposal of the shares of a tax consolidated loss-making subsidiary, entailing the deduction of the capital loss following an increase and reduction of share capital
Optimization of local taxes of the 3 French plants
Reimbursement of excess CIT paid further to mergers achieved since the 3 preceding years
R&D tax credit
Debt push initiatives complying with French thin capitalization rules
• Transfer Pricing documentation
Drafting of all the French mandatory (since 1st January 2010) transfer price documentation, justifying the economic rationale and the level of remuneration of all intra-group transactions.
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Caisse Nationale des Caisses d'Epargne - BPCE
- Fiscaliste
2006 - 2009
Manager in charge of Subsidiaries, and Tax consolidation (9 people in the Tax team)
Central body of the Caisse d’Epargne group, third largest banking group in France
Total assets b€ 1 147, tier 1 capital b€ 41, 127 000 employees
More than 100 banking, insurance, finance and real estate subsidiaries
• Management of the tax consolidation (80 consolidated companies)
Optimization of the income tax burden
Reporting of current and deferred taxes, and of tax consolidation gains according to IFRS regulations
Compliance: drafting and control of the tax returns
• Contribution to restructuring projects and tax due diligences
Merger of Banque Federale des Banques Populaires with Caisse d’Epargne in 2008/2009, resulting in the creation of BPCE, second French banking group
Contribution of real estate assets to Nexity in 2007
Participation to the creation and structuring of the Corporate and Investment bank Natixis in 2006
• Support and assistance of the CNCE and its subsidiaries
Regarding tax audits and disputes, and tax compliance
• Tax analysis of the group’s operations
Divestments of assets or shares
Tax optimization schemes (tax deduction of long term capital gains)
Analysis and tax recommendation regarding new financial products (centralized cash pooling,)
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Deloitte & Touche - TAJ
- Avocat fiscaliste
2002 - 2006
Senior then Supervisor tax lawyer in the “Corporate Tax” department, specialized in corporate income tax (CIT) and international taxes
• Tax Due diligences and studies of tax acquisition structures (water supplying group SAUR, First French undertaker’s group PFG)
• Follow-up of the tax situation of international groups
Financing and intra-group relations – thin capitalization rules
Restructuring (national or transnational mergers and winding up)
Identification and follow-up of specific tax risks
• Tax audits and tax dispute
Assistance with the drafting of tax memorandum and defense of the company in tax committees
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Arthur Andersen International
- Avocat *
2000 - 2002
Junior tax lawyer in French and international corporate tax: restructuring operations, CIT studies, annual tax reviews , and tax due diligences