Pierre Ullmann

Partner

Paris
Willkie Farr & Gallagher LLP
21-23 rue de la Ville l'Evêque
75008 Paris
T +33 1 53 43 4544
F +33 1 40 06 9606
pullmannwillkie.com

Pierre Ullmann is a partner in the Tax Department. He advises public and private companies on the French and international tax law aspects of mergers & acquisitions, combinations, restructurings and debt financing. He has a specific experience on transactions involving construction and real estate investment projects, particularly on behalf of foreign investors and foreign funds trough the use of French REITs equivalent or standard acquisition vehicles. Pierre regularly assists clients in tax litigations and negotiation of rulings with the French tax authorities and advises individuals on income tax, wealth tax and estate tax issues.

Highlights

Pierre Ullmann is a partner in the Tax Department. He advises public and private companies on the French and international tax law aspects of mergers & acquisitions, combinations, restructurings and debt financing. He has a specific experience on transactions involving construction and real estate investment projects, particularly on behalf of foreign investors and foreign funds trough the use of French REITs equivalent or standard acquisition vehicles. Pierre regularly assists clients in tax litigations and negotiation of rulings with the French tax authorities and advises individuals on income tax, wealth tax and estate tax issues.

Selected Significant Matters

  • Advised the French company Apsys in connection with several transactions, including:
    • the structuring of the acquisition vehicle of the largest Paris shopping center in joint venture with a German open investment fund and a Chinese sovereign fund;
    • the structuring and financing of joint ventures with institutional investors to develop, finance and operate commercial centers in France (Caen, Soyaux, Saint-Nazaire, Metz, Paris-La Villette) and Poland.
  • Advised ISS on the tax issues raised by the exit of the French consolidated tax group of its French landscaping business unit resulting from its divestment to Chequers Capital.
  • Advised the French Company CMA CGM, the world’s third largest container shipping company in connection with several transactions, including:
    • the structuring of a $600 m securitization program of a pool of freight receivables generated by its activities and those of four of its wholly-owned French and non French subsidiaries;
    • the restructuring of its direct and indirect shareholdings in certain French and non French container terminal operations in a dedicated holding company prior to the sale of a 49% shareholding to a third party Chinese investor;
    • Tax treatment of financing of vessels by means of finance leases entered into with tax transparent entities created by financing banks;
    • the issuance of high yield bonds quoted in Luxembourg.
  • Advised the investment fund Patron Capital II LP in connection with several transactions, including:
    • acquisition of a real estate group of companies followed by an election for the French REIT tax exempt status ("Sociétés d’Investissements Immobiliers Cotées" –SIIC) and a subsequent disposition of the investment;
    • acquisition of a large portfolio of French real property in a property dealer transaction through a Danish company followed by an allocation of the assets to a French branch.
  • Advised Goldman Sachs, Colony Capital and Merchant Equity Partners in connection with the acquisition of the French company BUT SA.
  • Advised the Italian oil company ENI on the VAT and corporation tax aspects involved by the setting up of a gas trading branch in France; negotiation of a unilateral Advance Pricing Agreement with the French tax authorities.
  • Advised the French bank Société Générale in connection with the refinancing of ITT’s US real estate assets through a leverage finance lease.

Prior Experience

Prior to joining Willkie, Pierre led the tax law practices in the Paris offices of Brandford Griffith & Associates (2003-2006) and at Jones Day (1990-2003).  He was also previously a senior partner at Bureau Francis Lefebvre (1983-1990) and a partner at Goldsmith, Devolvé & Associates (1975-1983).

Selected Professional and Business Activities

Pierre is a member of the International Tax Association  (IFA) and the International  Bar Association, and is a member of the Board of Directors of the Institute of French Tax Lawyers (IACF).  He previously served as an assistant professor of the doctoral program of tax law, HEC Faculté de Droit de Paris (1990-1999), and frequently addresses prominent seminars and conferences on tax law.

Selected Publications and Lectures

SELECTED PUBLICATIONS

  • 2009: "Aspects fiscaux des Fusions Transfrontalières des Sociétés de Capitaux," Journal des Sociétés (following the implementation in 2008 of the EU Directive 2005/56/CE on transnational mergers).
  • 2002: "the Use of French Holding Companies by Multinational groups," The International Tax Journal, Fall 2002.
  • 1993: Coordinator of the Chapter relating to transfer pricing of the White Paper on French International Tax issues issued by the CNPF (Confederation of French Enterprises).

SELECTED SPEAKING ENGAGEMENTS

  • 2012: IACF Conference: "Impact of Double Tax Treaties and E.U. Directives on the French Tax Treatment of Withholding Taxes and Tax Credits."
  • 2008: IACF Conference: "French tax treatment of transfer of seats of companies into France or outside France, with or without transfer of assets."
  • 2006: IACF Conference: "The Judge faced to Tax litigation: Interaction between the National Judge and the European Judge."
  • 2003: IACF Conference: "Use of Sociétés de Personnes and Partnerships in the national and international context."
  • 2003: ABA Spring Conference, Los Angeles: "Acquisition of a French Public Company by a United States Buyer; Deal Structures and Tax Considerations."

Recognition, Honors & Awards

Chambers Europe (2014) and Chambers Global (2014) rank Pierre among the leading individuals practicing Tax Law in France.

Recognition, Honors & Awards

Chambers Europe (2014) and Chambers Global (2014) rank Pierre among the leading individuals practicing Tax Law in France.

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