Fanny Combourieu

Partner

Head of Tax, France

Elected Member of DLA Piper International Board

Fanny has great team leadership and tax technical knowledge. She is proactive and delivered on a very tight schedule.
Client, Chambers Europe 2023
About

Fanny Combourieu has a proven track record in corporate taxation, but more particularly in transactional taxation in France and abroad.

For more than twenty years, Fanny has been involved in the tax structuring of M&A transactions for investment funds and institutionals in all types of assets:

  • Private Equity (LBO and external growth transactions)
  • Infrastructure
  • Real Estate

Fanny also has extensive experience in tax audits and litigation.

She advises investment funds, institutional investors, banks, financial institutions, corporations, family offices and high net worth individuals.

Professional QualificationsAvocate admitted to the Paris Bar

EXPERIENCE

Fanny has worked on the structuring of numerous transactions in particular in relation to private equity, infrastructure and real estate assets such as:

Private Equity:

  • Advising Circana (IRI), following the acquisition of NPD group, on the coordination, structuring and reorganisation of the two groups in 9 jurisdictions (US, Canada, Australia, Spain, Italy, France, Germany, UK and the Netherlands).
  • Advising Eurazeo and Naxicap funds in the context of the acquisition of the 2RH group and the external growth operations carried out by the group in Italy (acquisition of the Nolan group), in the United States (acquisition of Troy Lee Designs) and in Central Europe (acquisition of Casco).
  • Advising MML Capital in the context of the acquisition, alongside Metric Capital Partners, of the GPS group, a metal crate rental company for the transport of raw materials; and in the context of their investment in Arηs Group, a fast-growing European IT services firm
  • Advising The Carlyle Group in the context of the acquisition of Euro Techno Com (supplier of passive equipment for telecom networks) and the sale of the group to Cinven as well as in connection with the group's external growth operations in the United States (acquisition of Comstar and Walker) and in Poland (acquisition of Klonex).
  • Advising The Carlyle Group in the context of the acquisition of LPG, HGH, SESAMn, Inova and Envea and the sale of Prima XI and Prima Compliance to Duck Creek.
  • Advising Eurazeo Brands in the context of the acquisition of Axel Arigato and UltraPremium Direct.
  • Advising Mérieux Equity Partners in the context of its investment in Janvier Labs and in the Serb Group.
  • Advising the management of Circet in the context of the sale of Advent's stake to ICG and their reinvestment in the group.
  • Advising the management of B&B in the context of the sale of the group by PAI Partners to Goldman Sachs.
  • Advising 21 Invest in the context of the acquisition of the Landanger group.
  • Advising Lion Capital in the context of the acquisition and refinancing of the DMC group.

Infrastructure:

  • Advising Hy24 within the framework of the first investment of its fund dedicated to equipment and technologies for decarbonized hydrogen (Clean Hydrogen Equipment Fund) in the Norwegian company Hexagon Purus.
  • Advising Hy24 (Clean H2 Infra Fund) on its strategic equity investment into InterContinental Energy.
  • Advising Hy24 (Clean H2 Infra Fund) in the context of the joint-venture between Everfuel and Hy24 who create a €200 million joint venture to accelerate the deployment of green hydrogen production infrastructure in the Nordic countries. Also advising Hy24 on the joint-venture’s first acquisition of Phase 1 of the HySynergy green hydrogen production project, a 20MW electrolyzer located in Fredericia, Denmark. 
  • Advising Vauban Infrastructure Partners in the context of the acquisition of Financière Groupe Proxiserve, a major player in energy services in France, from Asterion Industrial Partners.
  • Advising Mirova and Asterion Industrial Partners in the context of the acquisition of the group Proxiserve, a major player in energy services in France.

Real estate:

  • Advising AXA in the context of the acquisition of "Dolphin Square", the largest private rented residential complex in London for AXA investors located in different jurisdictions.
  • Advising Ares in the context of the acquisition of the shares of a French SPPICAV (OPPCI) owning indirectly a portfolio of six logistics/warehouse assets from OJIREL managed by ALDERAN.
  • Advising Harbert Management Corporation in the context of the acquisition and development of several logistics' warehouses on a plot of land located in France.
  • Advising Cain International in the context of the acquisition of its first office building in France through a JV with the asset manager FREO Asset Management.
  • Advising Real IS in the context of the acquisition of office buildings in Paris (Faubourg asset) Lyon (located Quai Perrache – Convergence buildings, and one office building ) and Marseille (located bd de Dunkerque – the Grand Large buildings), and in the context of the sale of an office building in Paris (avenue Hoche)
  • Advising Union Investment in the context of the acquisition of the hotel operated by Melia in La Défense and sale of numerous assets (Le Prime, Capella, Arc de Seine, Altaïr, Aile Sud, Le Cap, Le Wilson...).
  • Advising Barings on multiple acquisitions, including the purchase of a 23,000 sqm (grade A) logistics warehouse in Nanteuil-le-Haudouin, a 6,500 sqm (grade A) office space in Pré-Saint-Gervais, and a 22,500 (grade A) sqm warehouse in Savigny-le-Temple.
Languages
  • French
  • English
Education
  • Université Paris-Sud Postgraduate Studies (DESS), International Tax Law, 1994 - 1995
  • HEC Paris, Major in Tax and Law, 1992 - 1995

Awards

Team recognitions

  • Chambers Europe – Tax – Band 4, 2024
  • Legal 500 – Tax – Tier 3, 2024
  • International Tax Ranking - General corporate tax – Tier 3 – 2024
  • International Tax Ranking - Transactional tax– Tier 2 - 2024
  • International Tax Ranking - Transfer pricing – Tier 3 - 2024
  • DLA Piper has strong expertise in the tax structuring of investment funds. The team is well equipped to assist clients with the tax aspects of M&A and private equity transactions in addition to tax audits. The law firm is a popular choice among international banks, private equity and asset management firms.” - “They are attentive to our needs and responsive.” - Chambers & Partners 2023
  • The team is used to structuring investment funds and can therefore explain our challenges to its counterparties abroad for our operations outside France.” - The Legal 500 EMEA 2023

Individual recognitions

  • Chambers Europe – Band 4 – Tax, 2024
  • Legal 500 – Private Equity Tax - Leading Individual, 2024
  • Best Lawyers – Tax Law – each year since 2017
  • Best Lawyers – Private Equity Law – each year since 2014 
  • Who’s Who Legal - Expert in Corporate Tax in France
  • Fanny has great team leadership and tax technical knowledge. She is proactive and delivered on a very tight schedule.” - “Fanny Combourieu leverages her tax knowledge to assist clients with acquisitions and refinancings. She regularly acts for asset management companies and private equity houses. One client says: "She is available, involved and technically excellent.” - Chambers & Partners 2023
  • DLA Piper has key strengths in the private equity sphere […] For transactional private equity tax work, practice head Fanny Combourieu is highly knowledgeable and regularly involved in mid-cap transactions, while also advising on large-cap deals.” - “Fanny Combourieu and her team are involved, technically sharp lawyers, reachable and business-oriented.” - The Legal 500 EMEA 2023

Publications

  • Loi de Finances pour 2024, 12 January 2024
  • Projet de Loi de finances pour 2024 : des changements significatifs pour les entreprises et les particuliers, 04 October 2023
  • "DAC 6 : Beaucoup de travail pour rien ?", Les Echos Capital Finance, February 2021
  • "Loi de Finances pour 2021", DLA Piper Insights, January 2021
  • "Les entreprises face au Covid-19 : quelles mesures fiscales?", DLA Piper Insights, March 2020
  • "France publishes transposition order to implement EU DAC6 directive into domestic law", DLA Piper Insights, December 2019
  • "Loi de Finances pour 2020", DLA Piper Insights, February 2020
  • "Déclaration des dispositifs fiscaux potentiellement agressifs (DAC 6) : l'ordonnance de transposition est parue", DLA Piper Insights, October 2019
  • "Loi de finances pour 2019 - Mesures fiscales intéressant les entreprises", DLA Piper Insights, January 2019
  • "Loi de finances pour 2019 - Mesures fiscales intéressant les particuliers", DLA Piper Insights, January 2019

Seminars

  • IPEM (International Private Equity Market), Cannes and Paris, France, each year
  • MIPIM (International Market for Real Estate Professionals), Cannes, France, each year
  • Expo Real (Real Estate Fair and Conference), Munich, Germany, each year

Prior Experience

Before joining DLA Piper, Fanny was a partner at several high-profile international firms, based in Paris.

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