Corporate Tax

Our firm deals with all issues related to direct and indirect taxation applicable to companies, whatever their activity: commercial, industrial, agricultural, liberal professions, etc.

Our interventions cover all taxes applicable to our clients: Corporate tax, value added tax, territorial economic contribution, payroll tax, withholding tax, etc.

Our firm provides real expertise to groups of companies and advises them in particular on tax consolidation, intra-group flows and restructuring operations (mergers, demergers, spin-offs, etc.).

We also advise on the tax aspects of employee profit-sharing: setting up stock option plans, bonus shares, company creator share subscription warrants and employee savings plans, etc.

Our experience :

  • Analysis of the accounting and tax treatment of intangible asset acquisition transactions for a group listed on the CAC 40.
  • Review of financial tax issues for a company operating in the field of means of payment.
  • Review and modelling of the tax impacts of the regulation limiting interest deduction for investment funds.

International Tax

We act in international tax matters both for French tax residents, companies or individuals, having activities or assets abroad, and for foreign tax residents participating in operations in France or owning assets in France.

In particular, we act in the following areas

  • Assistance and advice for the establishment of French companies abroad or foreign companies in France
  • Management of international flows (dividends, royalties, interest) and their tax impact
  • Optimisation of the effective tax rate of international groups
  • Transfer pricing management: implementation of transfer pricing policies, analysis of the tax risks inherent in intra-group transactions, implementation of treaty means to eliminate double taxation,
  • Support for staff mobility policy
  • International tax optimisation

Our experience :

  • Advising a company listed on the CAC 40 in the context of the structuring of its international royalty and dividend flows
  • Analysis and implementation of an Asian trading subsidiary for a French SME
  • Tax aspects of a project for the acquisition of a real estate portfolio by foreign operators

Individual Tax

We advise numerous clients on the management of their income tax and wealth tax. We act either in the context of our clients’ current activities, or prior to or following exceptional operations such as the sale of companies or real estate assets.

We also assist in asset reorganisations in order to prepare for the transfer of family businesses or family assets in the best possible legal and tax way. In this context, we are led to understand the various legal, financial and tax impacts of the reorganisations that we recommend and implement.

We work in France and on tax issues with an international dimension for French or foreign tax residents. Our team is composed of former wealth engineers from leading institutions.

 

Our experience :

  • Performance of audits and wealth assessments
  • Analysis and advice to a family holding company in the context of a transfer of a major private estate located in Saint-Germain-des-Prés (value of the estate: €50 million)
  • Advising a manager and sole shareholder of an SME in the sale of its operating companies: structuring of the sale transaction, contribution of part of its shares, organisation of donation(s) in coordination with its Notary and monitoring of reinvestments (value of the company: €10 million)
  • Optimisation of the IFI of managers who have sold their professional shares
  • Setting up of the protection of the spouse and more generally of the family, advice on matrimonial regimes, estate planning
  • Defending the interests of a family branch in the context of the negotiation of a shareholders’ agreement and the implementation of a Pacte Dutreil ISF (company value over 200 M€)
  • Assistance to foreign tax residents making real estate acquisitions in France on both a private and professional basis
  • Structuring and optimisation of management packages

Tax audits and Litigation

We assist our clients, companies, individuals and associations, in their relations with the tax authorities. Our work covers the following aspects in particular:

  • Tax audits of individuals: assistance in pre-litigation and litigation procedures
  • Corporate tax audits: assistance in the context of adversarial or non-adversarial procedures (opposition to tax audits, ex officio taxation procedures, abuse of rights, etc.)
  • Assistance during the implementation by the tax administration of any type of investigation procedure within its competence (search/home visit, right of investigation and communication, etc.)
  • Assistance in regularisation procedures (wealth tax, accounts held abroad, etc.)

Our experience :

  • Successful management of a procedure for the repression of abuse of rights in the context of a transfer transaction
  • Defending the interests of a holding company and its partners with regard to an IS and ISF audit
  • Defending a listed group in a dispute relating to transfer pricing, tax consolidation, proof of deficits