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Tax law

The firm’s tax-related activities have five major focuses:

 

The tax team has solid experience in these areas both when it comes to providing counsel and in litigation. It supports clients by stressing a pragmatic approach to cases and always working closely with the finance, accounting and legal teams. The tax team also systematically works closely with the mergers & acquisitions, employment law, commercial law and litigation teams in order to provide clients with comprehensive solutions.

Corporate taxation

  • International taxation, transfer pricing (method selection, benchmarks, documentation, tax audits), taxation of flows (dividends, interest, fees), localization of intangible assets, and cross-border restructuring.
  • Assistance and structuring of acquisitions/sales, tax due diligence, structuring, financial simulation tax analysis, liability guarantees, and bank relations.
  • Contract taxes (VAT, registration fees, withholding taxes).
  • Corporate taxes (taxable income, local taxation, VAT situation) and tax consolidation management.
  • Assistance with investments outside of France (coordination with foreign counterparts, tax structure for France and the company’s country of operations).
  • Assistance with foreign investments in France (branch/subsidiary, indebtedness, tax consolidation).
  • Relations with the tax authorities (including tax rulings).
  • Tax audits: assistance, negotiations during appeals to higher authorities, and litigation before the administrative courts.

Corporate managers/executive and private investors taxation

  • Assistance establishing an LBO: manager structure, financial incentive tools (e.g. start-up stock options – so-called “BSPCE”, allocation of free shares – “actions gratuites”) devised in cooperation with the mergers & acquisitions / corporate and employment law teams.
  • Company sales, capital gain and wealth tax issues, assistance in negotiations and post-sale follow-up.

Patrimonial/family business and individual taxation

  • Patrimonial restructuring (shared gifts, structuring of investments, real estate management)
  • Wealth tax management.
  • Departure from or arrival in France and tax residence.
  • Nonresidents’ taxation.
  • Tax regularization procedure of undeclared funds located abroad.
  • Tax audits.

Taxation of foundations and nonprofit organizations

  • Taxation of foundations in VAT, corporate taxes, economic contribution (“CET”).
  • Relations with the tax authorities (including advance rulings).

Taxation of local communities/municipalities and public agencies

  • Taxation of local communities and public agencies in VAT (including the specific VAT compensation fund – FCTVA), corporate taxes and local taxes.
  • Relations with the tax authorities (including advance rulings).

Drawing on the support of foreign colleagues in the global alliance of the Mackrell International network, the tax team works on international transactions.