International Tax 2026

INTRODUCTION

Contributed by: Laura Nguyên-Lapierre and Hanna El Rouah, Baker McKenzie

Baker McKenzie is represented in 44 countries and has a leading global international tax and transfer pricing practice, providing clients with world-class service in all facets of transfer pricing. Supported by more than 240 advisers, lawyers and economists, the firm's transfer pricing team advises global companies on transfer pricing matters including design/planning, financial modelling, implementation, documentation, audit defence and litigation. It has extensive expe- rience in competent authority procedures and has successfully accompanied and advised clients in

numerous sizable and high-profile advance pricing agreements and mutual agreement procedures. Bak- er McKenzie's economists specialise in international tax and work in close co-operation with transfer pric- ing lawyers, providing economic modelling that takes into account specific international tax requirements. Its international tax experts have a unique awareness of international transfer pricing policy. As a law firm, Baker McKenzie's advice is legally privileged subject to local laws and regulations; and its lawyers can liti- gate against tax authorities if disputes arise.

Contributing Editors

Laura Nguyên-Lapierre has 15 years' experience advising clients on international tax and transfer pricing

Hanna El Rouah practices focuses on tax dispute resolution and reassessment and international tax law matters. Hanna assists

matters, with a focus on dispute prevention and resolution (mutual agreement procedures, arbitration and advance pricing agreement procedures) across a range of industry sectors, including digital economy, consumer goods, tourism and asset management. Laura regularly assists clients in relation to international tax matters including tax treaty analyses, conversion of sales structures, risk assessment in relation to permanent establishment, tax consequences of global mobility, etc. Laura is also involved in international tax policy initiatives with national governmental bodies and international intergovernmental bodies. She regularly writes articles published in French and international specialized press and speaks at conferences on international tax topics. Laura graduated from HEC Business School and the Paris II Panthéon - Assas University, she is admitted to the French (Paris) bar.

multinational enterprises in the context of: tax audit prevention, assistance in the context of search and seizure procedures, following up tax audits in an international context, negotiations with the French tax administration and tax litigation. She has also developed expertise in the Technology industry, assisting clients on international tax controversy matters, including permanent establishment and transfer pricing confidential issues. She assists multinational enterprises in their relationships with the French tax administration including in the context of tax audits, settlements and tax controversies in France as well as on various other tax matters.

Baker McKenzie 1 rue Paul Baudry 75008 Paris France Tel: + 33 1 4417 5300 Fax: + 33 1 4417 4575

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