Our transversal approach to taxation aims to find innovative and secure solutions in connection with your complex operations in France and abroad.
Taxation is now one of the most structuring parameters, in financial terms and in terms of risks, of operations involving companies and individuals. Our approach, based on the knowledge of business challenges, the identification of truly efficient solutions, and the evaluation of risks, is designed to help you make these complex and essential choices. In this respect, we are committed to providing clear and precise advice.
Our teams of tax lawyers work with you across borders in the completion of all your complex projects.
We advise major French and foreign groups, investment funds, company directors and family shareholders on all their tax issues, whether French or international, thanks to our “Best friends” networks: WSG, ELG,…
We also represent their interests in the context of tax audits and litigation procedures, as well as in negotiations with the authorities to obtain approvals or tax rulings.
TAXATION OF MERGERS AND ACQUISITIONS
- Acquisition audits (corporate tax, VAT, 3% tax, withholding tax, registration tax, sectoral taxes, etc.);
- Tax structuring of acquisitions and financing (management of regulatory constraints on financial flows, limitation of tax deductibility of financial expenses, tax consolidation, etc.);
- Tax structuring of restructurings (management of the consequences in terms of tax consolidation, tax loss carry-forwards, tax approvals, etc.);
- Tax management of the implementation of acquisition or restructuring structures (tax consolidation, withholding taxes, financial flows, etc.);
- Assistance in real estate transactions (audit and structuring of acquisitions, disposals, setting up of dedicated investment vehicles, etc.);
- Implementation of employee and/or management incentive mechanisms (free shares, management package, etc.);
- Determination of individual and overall results of tax consolidation groups;
- Follow-up of tax obligations in terms of VAT, contribution on corporate added value, property taxes, 3% tax, withholding tax, registration fees, etc.
TAX MANAGEMENT OF INTERNATIONAL COMPANIES
Our tax services also cover assistance to French and international group managers in the context of their tax management and in particular:
- Taxation of company executives (structuring of their participating interests, wealth tax issues, international mobility, remuneration and management packages, etc.);
- Structuring and transfer of family groups (tax management of financial flows, Dutreil Agreements, international issues, etc.);
- Tax management of private client assets (wealth tax, inheritance / donations, organization of asset structures, real estate investments, tax returns, etc.).
REAL ESTATE TAXATION
- Structuring of French (SCPI, OPCI, SIIC, FIA...), German (KG, KAG...), European (Luxembourg) real estate funds;
- Taxation of Mergers & Acquisitions in real estate (Taxation of real estate transactions: asset deal and share deal);
- Taxation of cross-border real estate transactions;
- Taxation of the financing or refinancing of real estate assets (determination of deductible financial expenses, monitoring of the risk of undercapitalization, etc.);
- Taxation of investment and real estate transactions;
- Relations with the tax authorities (tax rulings and requests for formal positions, tax approvals in the context of restructuring, complaints regarding withholding tax, etc.);
- Tax compliance and monitoring of tax liabilities;
- Analysis of the contractual documentation of real estate funds;
- Taxation of real estate assets (transfer tax, property tax, VAT, 3% tax, territorial economic tax, urban planning tax, office tax, etc.);
- Real estate VAT;
- Tax litigation.
INNOVATION TAXATION: START-UPS & GROWTH COMPANIES
- R&D taxation, French and European innovation tax credit;
- Taxation and structuring of fundraising (share and bond issues);
- Transactional taxation and financing of acquisitions;
- Searching for subsidies associated with innovation (PM’Up, Innov’Up, European programs, etc.);
- Structuring of national and international executive compensation;
- Employee shareholding, social charges;
- Digital organization of legal and tax duties.
CRIMINAL TAXATION LAW
Search assistance in the preparation, support and litigation of:
(i) criminal searches, home visits and seizures in the context of proceedings in:
- preliminary investigation (art. 76 of the Code of Criminal Procedure) ;
- flagrante delicto investigation (art. 56 and following of the Code of Criminal Procedure);
- investigation (art. 92 and following of the Code of Criminal Procedure);
(ii) home tax visits (art. L16B of the Tax Procedure Handbook).
Assistance during criminal proceedings, preparation of hearings, relations with the prosecutor, the investigating judge and preparation and assistance of clients at all stages of the proceedings in preliminary, flagrante delicto or investigative inquiries:
(i) investigative deeds:
- open hearings, police custody, interrogations, witness hearings;
- judicial requisitions ;
- expert reports;
- transportation, observations, searches and seizures ;
- judicial information;
- technical and scientific examinations ...
(ii) various requests:
- additional investigative deeds;
- status of the procedure, foreseeable time of completion of the procedure;
- access to the file and copies of documents (investigation);
- dismissal of the case (investigation) or discontinuation of the proceedings (inquiry) / referral to the competent jurisdiction (criminal court).
Risk audit: acquaintance with the elements of the file, evaluation of the criminal risks, criminal qualification of the facts
Negotiation of the CJIP (Judicial agreement in the public interest) and CRPC (Plea-bargaining)
Preparation and assistance of clients at all stages of negotiations with the Public Prosecutor’s Office
LITIGATION & TAX AUDITS
Our firm is recognized as one of the leading litigation firms on the French market in business law in general and in tax law in particular.
Our lawyers combine a high level of legal expertise with a thorough understanding of the economic stakes of our clients faced with complex litigation before national and international courts.
We are also committed to building risk anticipation strategies with you. The litigation dimension is systematically integrated into the firm’s advisory activity in all its jurisdictions.
If you are a company director, a manager, a shareholder of a family group or an individual, our team will assist and advise you at all the major stages of your company’s life and that of your family:
- Optimization of the compensation of executives and managers (analysis and implementation of management packages, stock option and free share plans as well as any other compensation mechanisms);
- Advice to family entrepreneurs and managers in the context of company sales and restructuring operations (LBO, LMBO, etc.);
- Development of customized asset structuring (civil companies, trusts, partnerships, etc.);
- Preparation of asset transfers (Dutreil agreements, shared gifts, creation of foundations/endowment funds, etc.);
- Assistance in the definition of family governance and the implementation of appropriate tools;
- Transfer of residence, assistance in expatriation and impatriation, preparation of tax returns (wealth tax and income tax) for residents and non-residents, regularization of foreign assets as well as inheritance and tax structuring of your assets in France.