Hanna El Rouah

Hanna El Rouah

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

Biography

Hanna El Rouah practices in the Tax Group of Baker McKenzie in Paris. Her practice is focused on tax dispute resolution and reassessment and international tax law matters.

Hanna graduated from the University of Aix en Provence (Master 2 in Business Tax Law and Business Law) and from the University of Hong Kong (LLM).

Hanna joined the Firm in 2017. Before that, Hanna did multiple internships in tax departments of multinationals.

Practice Focus

Hanna 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
  • tax litigation.

She has also developed expertise in the TMT industry, notably assisting clients in international tax controversy matters, including permanent establishment and transfer pricing confidential issues, over the last few years. She assisted multinational enterprises (performing their activities in particular in the areas of the digital economy and the TMT 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

Hanna has notably been distinguished in the Best Lawyers 2024 edition "Ones to Watch in France" in the field of tax.

Admissions

  • France (2017)

Education

  • City University of Hong Kong (LLM) (2015)
  • University of Aix-Marseille (Master 2, Law and Corporate Taxation) (2014)
  • University of Aix-Marseille (Magistère Business Law, Taxation and Accounting) (2014)
  • Ecole Normale Supérieure de Cachan (Preparatory Class, Law-Economics option) (2011)

Languages

  • English
  • French
  • Co-author, "Literal interpretation of tax treaty: examples from Brazil, Turkey and China," Feuillet Rapide Fiscal Social, December 26, 2024
  • Co-author, "The right to make an error: Between encouraging tax compliance and defending taxpayers acting in good faith," Option Finances, September 4, 2023
  • Co-author, "VAT and characterization of a fixed establishment: The same means cannot be used twice!" Revue de droit fiscal, October 27, 2022
  • Co-author, "Right to make an error for the permanent establishment of a foreign digital service provider," Feuillet Rapide Fiscal Social, January 27, 2022
  • Co-author, "Conversant Ltd case: A decision that will change the face of permanent establishment?" Feuillet Rapide Fiscal Social, January 14, 2021
  • Co-author, "Permanent Establishment: An Extensive Approach Adopted by the French Supreme Court," Bloomberg Tax, Tax Management International Journal, December 31, 2020
  • Co-author, "Deemed distributed income: What are the rules for taxing the master of the business in the presence of a permanent establishment of a foreign company?" Droit Fiscal no. 25, June 18, 2020
  • Co-author, "European Union law, the stopper of the 'stopper' rule?" Feuillet Rapide Fiscal Social, June 20, 2019
  • Co-author, "No sufficient means, no power to commit . . . no permanent establishment," Feuillet Rapide Fiscal Social, April 26, 2018