Serge is a manager at Fidal in Paris. He joined the transfer pricing department of the firm in late 2019, after working 5 years within the international tax team of CMS Francis Lefebvre Avocats.
Serge focuses mostly on transfer pricing issues, such as designing and implementing new transfer pricing policies or advising groups on updating or amending their existing policies. He also regularly advises groups on transfer pricing compliance issues, including the preparation of their transfer pricing documentations (Master File / Local File), economic analyses (including benchmarking studies), or other annual obligations such as the yearly transfer pricing declaration or the Country-by-Country Report. Serge is equally involved in assisting clients with their tax audits, whether via settlements or court litigation. He also has experience with Advanced Pricing Agreements and post-audit procedures such as MAPs.
Serge has worked on several high-profile litigations cases which were ruled on by the French Administrative Supreme Court, in particular on the subject of the deduction of interests from intragroup loans by French entities.
In addition to his focus on transfer pricing, Serge also regularly assists clients in other specific issues relating to international tax, such as identifying potential Permanent Establishments and how to deal with such situations, or application of French CFC rules.
Serge regularly publishes articles on these subjects and is listed as a contributor to the 2017 and 2018 editions of Duff & Phelp’s Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies. He is also involved in transfer pricing centric training sessions, both via certified training organisms or directly with companies.
Serge holds a Master in Business Law from Lille University (2013) as well as an LL.M. in Law and Tax Management from EDHEC Business School (2013) and is an attorney-at-law at the Hauts-de-Seine Bar in France.
A French native, Serge lived 9 years in Canada and the US and is equally fluent in French and English.