Ariane Calloud

Baker & McKenzie A.A.R.P.I.


Ariane Calloud practices in the Tax Group of Baker McKenzie in Paris.

Practice Focus

Her practice is focused on tax dispute resolution and reassessment and international corporate tax law.

Ariane particularly assists 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, Medias and Telecommunications industry.

She is member of the Baker McKenzie EMEA Tax Dispute Resolution Steering Committee.

Representative Legal Matters

She has assisted numerous clients in international tax controversy matters, including permanent establishment and transfer pricing confidential issues, over the last few years.

Her clients are multinational enterprises performing their activities in particular in the areas of the digital economy and the TMT sector (assisting major leaders of this sector 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).

Professional Honors

International directories:

Legal 500


Ariane Calloud is ranked as Leading Individual in tax litigation
"Ariane Calloud and her team have been a very valuable support, demonstrating unfailing professionalism. Availability, rigour and pragmatism are their great strengths".

"Ariane Calloud: exceptional professionalism and excellence of her technical expertise, in particular in matters of tax control and litigation, but also on new and specialised subjects".

"The people we work with are technically excellent, but above all they are involved and passionate as if our business was theirs".

Ariane Calloud is ranked as Next Generation Partner in tax litigation
"Ariane Calloud […] display[s] extreme knowledge of tax law and build pragmatic solutions for the client".

Ariane Calloud is ranked as Next Generation Partner in tax litigation
"The exceptional and fully dedicated Ariane Calloud provides 100% reliable and strategic advice".

"The firm’s proficiency in handling high-profile tax audit and litigation work is also well known and it is notably managing cases dealing with 3% tax, permanent establishment and international tax issues. Leading names in the digital and retail sectors have entrusted the firm with some of their most sensitive cases. (...) Eric Meier and Régis Torlet, who are both ‘great listeners with broad knowledge’, are also highly regarded, as is Ariane Calloud".

"Its tax litigation team is second-to-none in France and it obtained a series of astonishing victories in 2017, including obtaining a groundbreaking victory from Paris’ first level of jurisdiction for client Google in challenging the French tax authority's allegations of permanent establishment in France. (…) Eric Meier, who ranks among the best in his field, Régis Torlet and Ariane Calloud are all highly recommended".

"The tax practice particularly stands out in the litigation area, certainly the best team in Paris, through the excellent Eric Meier, Régis Torlet and Ariane Calloud".

"Ariane Calloud is outstanding and has unique ability to focus on the minute detail while constantly considering the strategic objectives".

International Tax Review (ITR) 2013-2022
Ariane Calloud is designated as one of the tax highly regarded controversy leaders in France since 2013.

Women in Tax - Tax Leaders Expert Guide (ITR) 2015-2022
Ariane Calloud is designated as one of the women tax leader in France.
In 2020 Baker McKenzie is the law firm with the most women ranked in France since 2015.

Euromoney's European Women in Business Law Awards (2022)
Ariane Calloud was shortlisted in the Tax Dispute Lawyer of the Year category (individual nomination).

French directories:

Option Droit & Affaires (ODA) 2022
Ariane Calloud is ranked as Tier 1 lawyer in tax litigation and tax reassessment assistance.

Décideurs Stratégie Finance 2022
Ariane Calloud and the Tax litigation team are ranked as Leading and is ranked as Leading for the following categories: Large Tax Litigation and Tax Litigation assistance.

Professional Associations and Memberships

  • IACF (Institut des Avocats Conseils Fiscaux)
  • IFA (International Fiscal Association)


  • Paris~France (2005)


  • University of Paris (Dauphine) (DESS Corporate Law) (2004)
  • University of Paris (Pantheon-Sorbonne) (DEA Business Law) (2003)
  • University of Paris XI (Sceaux) (Master, Business Law specialization in Tax) (2002)


  • English
  • French

She was the IFA French Branch Reporter for the 2018 Seoul Congress for subject 1:

Anti-avoidance measures of general nature and scope -GAAR and other rules

She is the author of the following articles published in the tax specialized press:

  • "Potential Avenues to Resolve a Transfer Pricing Dispute", Ariane Calloud and Susan Ryba, Baker McKenzie Bloomberg Transfer Pricing Report 2022 - Tax Management International Journal - December 2022
  • "Transfer Pricing Disputes: what solutions in a changing international tax environment?", Ariane Calloud and Laura Nguyen-Lapierre, Option Droit & Affaires - September 12, 2022
  • "Comments on two years of application of the CJIP (i.e. criminal settlement) to facts which may be qualified as tax fraud", Eric Meier, Ariane Calloud and Mathieu Valeteau – Feuillet Rapide Fiscal Social – January 8, 2021
  • "Permanent Establishment: An Extensive Approach Adopted by the French Supreme Court", Eric Meier, Ariane Calloud and Hanna El Rouah, Tax Management International Journal – Bloomberg Tax, Vol. 50 - December 31, 2020
  • "Possible application of tax treaties to notional flows: a fine distinction to be made between legal and tax personality", Ariane Calloud and Mathieu Valeteau – Revue de droit fiscal – October 17, 2019
  • "PE: the importance of the factual analysis" (comment of the Google decision), Eric Meier and Ariane Calloud – Feuillet Rapide Fiscal Social – September 28, 2017