Strategy and Tax Management
- Choice of localization and implantation mode (corporations, partnerships, permanent establishments)
- Determination of the taxable income (management of tax losses, financing mode and deduction of interest)
- Management of tax consolidation groups (tax consolidation agreement, intra-group transactions)
- Tax management of financial flows (dividends, interest, royalties, intra-group services)
- Tax strategy and management in a global environment (applying international tax treaties, involvement of our foreign tax specialist contacts)
Taxation of Transactions
- Tax audit of purchases or transfers (drafting an audit report, monitoring the tax risks)
- Tax structuring and optimization of purchase and transfer transactions
- Approval requests filed with the tax authorities (transfers of deficits, mergers, partial contributions of assets)
- Reviewing the tax sections of the legal documentation for a purchase/transfer (shareholders’ agreements, Share Purchase Agreements…)
- Implementation of “management packages” (Preference shares,Bonus shares, BSPCE…)
Wealth Strategy and Management
- Gift and inheritance
- Dismemberments of ownership (company securities, real estate…)
- Transfers of companies (retirements…)
- Pactes Dutreil agreements (wealth tax and transfer duties)
- Tax domiciliation: outside of France (Belgium, Switzerland, Luxemburg, the USA, Great-Britain…); in France (favorable regime as regards income tax and wealth tax)
- Life insurance
- Artifacts, philanthropy, patronage, assistance in the implementation of endowment funds, foundations and associations
- Historical monuments, wine, agriculture and forest structures
- Trusts and fiducie
- Wealth strategy in a global environment (applying international tax treaties, involvement of our foreign tax specialist contacts)
Tax return obligations
- Income tax and wealth tax returns (residents and non-residents)
- Regularization of foreign accounts (simulation of the regularization cost, filing amended tax returns and monitoring the regularization procedure with the French tax authorities)
- Circumstantial and annual tax returns of trusts
Tax Audits
- Establishing the response strategy for the information requests and adjustments suggested by the French tax authorities
- Drafting the answers to the requests from the French tax authorities and actively monitoring the procedure with the French tax authorities (meeting requests, potential hierarchical recourses, participation in the various commissions, referrals to the tax conciliator, settlements)
Tax Litigation
- Establishing the strategy for presenting a contentious claim before the French tax authorities
- Drafting a contentious claim (developing arguments as regards the procedure and merits given French domestic and European Union case law)
- Referrals to courts (administrative or judicial) and monitoring proceedings
- Information of the clients regarding the opportunities of a tax relief, as a result, in particular, of favorable case law (e.g. a French legislation that is contrary to the fundamental freedoms of the European Union) and implementation of litigation proceedings
Tax Structuring
- Tax audit of a purchase or transfer (drafting an audit report, monitoring the tax risks)
- Taxation on the purchase and transfer of real estate (corporate income tax, VAT, registration duties, undertaking to build, purchase in view of a sale)
- Implementation of foreign purchase structures (Luxembourg, the Netherlands…)
- Taxation of flows as regards real estate structuring
- Structuring of real estate investments for resident and non-resident investors
- SIIC, OPCI regime …
- Analysis of a real estate preponderance as regards transfer duties and corporate income tax
Tax Return Obligations
- 3% tax on real estate owned in France
VAT
- Audit of the risks
- Optimization of the deduction rights
- Improvement/Management of the VAT and payroll tax pro rata allowance
- Assistance on the occasion of a tax audit
Other Taxes
- Transfer duties, CVAE (tax based on corporate added value), Excise, …