Tax Law

A high level of expertise is required to fully understand and master the increasing number of laws and regulations, international tax treaties and concepts involved in tax law.

In order to provide high-quality services and support, our Tax Law team draws on a range of high added value skills in corporate, personal and wealth and asset taxation. It has ample capacity to provide first-class support in these areas, whether assisting individual or corporate clients in developing a tax strategy, anticipating and managing tax inspections or dealing with tax disputes of all kinds.

Our tax lawyers also work with the support of the firm’s other departments and an international network of law firms to structure your merger, divestiture, private equity and wealth and asset management transactions.

In an ever-changing regulatory and tax environment, it is essential to get advice from the best specialists to ensure that all aspects of one’s tax affairs and issues are secure and optimized. Our team of specialists has the ability to handle all such matters at both national and international levels:

• Audit of internal tax risks and subcontractors’ compliance
• Audit of your IT tax tools
• Acquisition audit and Vendor Due Diligence (VDD)
• Tax management of intragroup flows and transfer pricing
• Tax management of tax losses
• Management of under-capitalization issues
• National and community VAT
• Operational customs issues (applicable tariffs, customs value)
• Tax treatment of R&D (intellectual and industrial property, research tax credit (CIR), innovation tax credit (CII), etc.)
• Compliance audit (“hybrid” directive, DAC6, etc.)
• Employee shareholding.

We advise executives, managers, private clients and family offices on:

• Compensation structuring (salaries versus dividends)
• Wealth and asset structuring (wealth tax/property wealth tax, gifts, inheritance)
• Management packages (bonus shares, founders’ share warrants (BSPCEs), performance shares)
• Management of personal holding companies
• Trusts and fiduciaries (reporting obligations)
• Philanthropy (foundations, endowment funds).

In partnership with our Corporate, Private Equity and Financing teams, we can provide you with unique expertise on the tax treatment of financial products, investment funds and project financing instruments.

Our specialists work closely with teams from our Corporate and Private Equity departments to offer the highest level of expertise regarding the tax implications of your national and international transactions (M&A, LBO, MBO, divestitures, restructurings, etc.). Depending on your needs, we can:

• Carry out an acquisition or sale audit (due diligence and VDD)
• Structure acquisition or disposal/divestiture transactions
• Structure internal reorganizations of groups in France and abroad
• Help foreign groups structure their investments in France
• Optimize sales of securities and assets
• Optimize the distribution of income (dividends, interest, royalties).

We have developed recognized expertise in the taxation of the property sector. We can assist you with all your tax issues at every stage of your projects:

• Acquisitions of assets, portfolios or companies
• Preliminary audits of real estate transactions
• Project financing
• Tax treatment of capital gains and rental income
• Tax treatment of SCIs (real estate partnerships), SIICs (listed real estate investment companies), OPCIs (real estate collective investment undertakings)
• Local taxes (territorial economic contribution (CET), land tax, tax on office premises (TSB), etc.)
• VAT on property, registration fees, taxes on profits made by property dealers
• Renovation (tax schemes applicable to Malraux properties and historic monuments).

The tax aspects of international expansion decisions are of crucial importance and must be considered very carefully. We can assist you with the configuration of your expansion strategy by comparing (benchmark) the tax arrangements and schemes of the target countries, providing a comprehensive analysis of the tax treaties between France and the countries concerned, and supporting you in all the administrative steps required to set up companies internationally.

We regularly work with major international groups. This collaboration has enabled us to develop sound experience in the management and optimization of international accounts. Depending on your requirements, we can assist you with:

• The structuring of financial links between subsidiaries and their group
• Intra-group financing agreements
• Approval requests
• The management of intra-community VAT
• The determination of transfer pricing
• The tax aspects of restructuring transactions
• The optimization of the tax burden, financing and indebtedness
• Day-to-day tax management (consolidation, taxes, etc.)
• Employees’ international mobility
• The acquisition of assets internationally.

Our teams can assist you with the auditing of your tax risks, advise you on risk minimization strategies, provide support during tax inspections, assist you in drafting replies to the authorities, help you find amicable solutions, or represent you before administrative or judicial courts. These activities include the following:

• Assistance with tax inspections regarding companies and individuals (verification of accounts and tax inspections regarding individuals (ESFP, Personal Tax Situation Inspection))
• Tax proceedings (including inspections and seizures)
• Pre-litigation assistance before the authorities (appeals and negotiations)
• Assistance before special turnover tax and direct tax joint committees
• Assistance in courts of first instance and on appeal
• Assistance in the specific area of inspections of computerized accounts
• Assistance in the area of criminal tax law.