Marie GERMAIN

Tax Lawyer with experience in the UAE, US and Europe

5 months CMA CGM Dubai

3.7 years DLA Piper Luxembourg

1.6 years KPMG Luxembourg

1 year Axelia Partners Boston, US

DLA Piper Luxembourg

• Providing tax structuring advice for multinational corporations, investments funds and financial institutions
• Drafting of tax memorandum covering the on-going taxation, repatriation of profits and exit taxation implications of the structure and including inter alia Luxembourg corporation taxes, ATAD, ATAD2, ATAD3, DAC6, VAT, and transfer pricing considerations
• Coordinating with Funds and Legal teams to assess the optimal structure for each client
• Calls and coordination with the client
• Providing tax advice to domestic and international clients (direct tax and indirect tax including transfer pricing)
• Drafting and reviewing funds, corporate and banking documentation from a tax perspective
• Funds documentation: limited partnership agreement, private placement memorandum/offering memorandum, side letter
• Corporate documentation: share purchase agreement, transfer of shares agreement, shareholder loan agreement
• Banking documentation: facility agreement, parent guarantee agreement, note purchase agreement
• Managing tax compliance (DAC6)
• Undertaking research on technical tax aspects (international tax and Luxembourg tax law)
• Monitoring European regulatory and tax changes and impact on structures through Luxembourg
• Training and managing interns and junior lawyers