Mary Bennett and Caroline Silberztein join Bakers from the OECD’s Centre for Tax Policy & Administration

Baker & McKenzie will strengthen its Global Tax Practice Group with the arrival this autumn of two top tax officials from the Organisation for Economic Co operation and Development (OECD). Mary Bennett, head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the OECD’s Centre for Tax Policy & Administration (CTPA), will rejoin the Firm as a partner based in its Washington, DC office, and Caroline Silberztein, head of the CTPA’s Transfer Pricing Unit, will join as a partner based in the Paris office.

“We are extremely pleased to welcome lawyers of the global stature and deep experience of Mary and Caroline into our tax practice,” said Richard Weisman, Chair of Baker & McKenzie’s Global Tax Practice Group. “Their technical skills and unparalleled policy insights will add a whole new dimension to the world-class tax services we provide to our clients.”

Ms. Bennett has more than 30 years of international tax experience. She was a partner based in Baker & McKenzie’s Washington, DC office before taking up her current position at the OECD in 2005. At the OECD, Ms. Bennett has overseen the organization’s work on its Model Tax Convention, including the major updates in 2008 and 2010 which introduced mandatory arbitration and new provisions on the attribution of profits to permanent establishments, and on its Transfer Pricing Guidelines. She has also been instrumental in deepening the OECD’s dialogue on tax treaty and transfer pricing matters with non-OECD countries. While at the Firm from 1990 to 2005, Ms. Bennett’s practice focused on international tax planning and controversy matters for both U.S. and foreign based clients. Chambers USA recognized her as one of America’s leading tax lawyers. Prior to that, she spent five years at the U.S. Treasury Department, where she served as the Deputy International Tax Counsel, and practiced international tax law with private firms in London and Boston.

Ms. Bennett is a frequent speaker and writer on international tax issues and an active member of several tax professional organizations, including the International Fiscal Association and the American Bar Association’s Tax Section. She taught Advanced International Tax at Georgetown University (2001-2004), was the 2005 Tillinghast Lecturer on International Taxation at NYU Law School, and delivered the 2010 Maarten J. Ellis Lecture at Leiden University’s International Tax Center. She holds an AB from Harvard University, a JD from Columbia Law School and an LL.M in Taxation from Boston University.

“Mary’s return to Washington and North America instantly enhances the outstanding depth of our team of 200 NA tax lawyers and economists and gives us unique insight into the tax and treaty policy of most major countries, including administrative and enforcement trends, dispute resolution approaches, case law development, and the likely direction of future international tax legislation in those countries,” said Len Terr, chair of the North American Tax Practice Group.

Ms. Silberztein has headed the OECD’s transfer pricing work for the past 10 years as Secretariat to the Working Party responsible for the Transfer Pricing Guidelines. Interacting with senior officials from all 34 OECD member countries and major emerging economies, she led the OECD discussions on the transfer pricing aspects of employee stock options and played the lead role in drafting and developing the consensus for the first major revision of the Guidelines since their publication in 1995, covering such critical topics as comparability, the use of profits methods and the transfer pricing aspects of business restructurings. She also has had responsibility for launching the organization’s current work on the transfer pricing aspects of intangibles and on the administrative aspects of transfer pricing.

Recognized as a global leader in the field of transfer pricing, Ms. Silberztein has written dozens of articles and has spoken at over 100 conferences around the world on transfer pricing topics. She has been a visiting professor in several European universities and has represented the OECD at the EU Joint Transfer Pricing Forum, the UN Committee of Experts Subgroup on Transfer Pricing and in other forums. Before joining the OECD, she practiced for 14 years as a corporate tax lawyer, and established and led transfer pricing practices at two major French firms. Ms. Silberztein is a graduate of the École Supérieure de Commerce de Paris.

Régis Fabre, Managing Partner of the Paris office commented: “As the most visible thought-leader in her field, Caroline is uniquely placed to develop and lead a premier transfer pricing practice. We are extremely pleased to welcome her as a partner in Paris. No doubt that Caroline will help us to further differentiate ourselves on cutting-edge international tax matters and the resolution of high profile tax disputes.”