Caroline Silberztein

Caroline Silberztein

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


Caroline Silberztein heads Baker McKenzie's international tax and transfer pricing practice in France. She assists multinational clients in risk assessment and management, the design and implementation of transfer pricing policies adapted to their business models, the drafting of documentation, as well as tax audits, litigation, mutual agreement procedures / arbitration and advance pricing agreements, both locally and globally. 

Practice Focus

Caroline was the Head of the OECD Transfer Pricing Unit from 2001 to 2011. She closely monitors international tax policy developments and helps her clients anticipate significant changes. 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 nominated by France 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. She also acted as an arbitrator for the Canada-U.S. Convention.

Professional Honors

Chambers Europe – France 2023

Caroline is ranked Band 3 in the Individuals section.

« Caroline Silberztein is particularly noted for her expertise in the field of transfer pricing and is highly sought after by international and domestic clients alike. »

"She is very proactive and understands our needs very well."
"She is clearly the star in transfer pricing."

  • The Paris Tax department is ranked Band 2

Legal 500 EMEA 2023

  • Caroline is ranked as « Leading individual » for Transfer Pricing and International Tax
  • Testimonials:

"The level of commitment is excellent."
"Caroline Silberztein stands out through her expertise in transfer pricing and the quality of her relations with the competent departments of the tax administration."

  • The Paris Tax department is ranked Tier 1.

International Tax Review (ITR) 2023

World Transfer Pricing Guide 2023 – Tier 1
"Highly regarded" for tax and transfer pricing matters
"Women in Tax Leader"

Décideurs Stratégies Financières & Fiscales 2023

Leading Firm for Transfer Pricing & International Tax

Best lawyers 2023

Caroline is once again ranked “Best Lawyers” for Tax.

Professional Associations and Memberships

  • International Fiscal Association
  • Institut des Avocats Conseils Fiscaux
  • IFA France Scientific Committee


  • Paris~France (1991)


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


  • English
  • French

Caroline Silberztein has written dozens of articles and spoken at over 200 conferences around the world on transfer pricing topics for various audiences (private sector, governments, academic). She is a regular lecturer on transfer pricing topics in several European Universities and in particular is in charge of transfer pricing seminars for M2 students at Paris II Pantheon-Assas University and at one of the French leading business schools (HEC).