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Caroline Silberztein

Caroline Silberztein

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

Biography

Caroline Silberztein heads Baker McKenzie's international tax and transfer pricing practice in France.

She assists multinational enterprises from a range of industries with transfer pricing risk assessment and management, design and implementation of transfer pricing policies, tax audits, tax litigation, mutual agreement procedures and advance pricing arrangements, on a local and a global basis.

Practice Focus

Caroline has an excellent track record in resolving transfer pricing disputes at pre-litigation and mutual agreement procedures / arbitration levels. She handles a large number of requests for mutual agreement procedures / arbitration and advance pricing agreements with the competent authorities in France and in other jurisdictions.

Caroline is a recognized contributor to international transfer pricing dialogue . She was the Head of the OECD Transfer Pricing Unit from 2001 to 2011 and, as a member of the UN Subcommittee on Transfer Pricing, one of the drafters of the 2013 and 2016 versions of the UN Manual on Transfer Pricing for Developing Economies.

Caroline is nominated on the list of independent persons eligible to act as arbitrators for the application of the EU Arbitration Convention and the EU Tax Dispute Resolution Directive.

Professional Honors

Chambers France 2026

  • Caroline is individually ranked Band 1 in the International Tax category.

Testimonials:

"Caroline Silberztein develops the commercial relationship with us as client. She is also reactive and can apply herself to the case at hand."

"Caroline Silberztein is a great expert in transfer pricing, she advises us on complex advanced pricing agreement procedures."

The Paris tax department received the 'Tax Law Firm of the Year' award by Chambers France Awards 2026.

Legal 500 EMEA 2026

  • Caroline is ranked as "Leading individual" for Transfer Pricing and International Tax.

    International Tax Review (ITR) 2026
  • Tier 1 for Transfer Pricing
  • Caroçline is recognized "Highly regarded" for tax and transfer pricing matters.

Décideurs Stratégies Financières & Fiscales 2025

  • Leading Firm for Transfer Pricing & International Tax

Best lawyers 2026

  • Caroline is ranked in the latest edition of the “Best Lawyers” Guide for Tax.

Professional Associations and Memberships

  • IFA - Member

Admissions

  • Paris~France (1991)

Education

  • École Superieure de Commerce de Paris (Europe Master Management) (1987)

Languages

  • English
  • French

Caroline is a regular contributor of articles in French and international tax magazines. She is a regular lecturer on transfer pricing topics in several European Universities and in particular is in charge of a transfer pricing seminar for M2 students at Paris II Pantheon-Assas University.