TAX

POSITIONING AND STRENGTHS

We provide our clients with expertise in the developing of tax strategies and management of tax audits and litigation, both in France and abroad.

The know-how of our team is the product of extensive corporate and industry experience, both in France and abroad. Our clientele is equally diverse, comprised of companies of all sizes, and leaders accross a range of business sectors.

SPECIFIC AREAS OF SKILL 

• International interests of French companies
  • Fiscal structuring of the investment according to expansion strategy and targeted objectives (subsidiary vs. branch, intercompany management, withholding tax issues, VAT and customs, taxation of "turnkey” projects, incentive regimes, taxation of the oil and mining sectors) ;
  • Assistance in implementation (registrations) and monitoring of fiscal obligations.
• Foreign companies interests in France
  • Tax structure of the investment in France according to specific objectives ;
  • Assistance in monitoring of French tax obligations.
• Acquisitions
  • Tax review of the acquired entity and drafting of due diligence reports ;
  • Negotiation of fiscal clauses in acquisition agreements and tax structuring of the acquisition.
• Tax inspections and tax litigation
  • Assistance to companies in the pre-litigation and litigation phases, especially for tax audits of companies on notably CIT, VAT and local taxes aspects ;
  • Assistance to individuals for study of personal tax situations (examen contradictoire de la situation fiscale personnelle).
• Management of day to day tax affairs
  • Advice and daily monitoring of the tax situation of companies and groups (financing of intragroup relations, restructuring, taxconsolidation) ;
  • Audit of the fiscal situation of companies (identification and monitoring of tax risks). 
• Individual taxation
  • Wealth tax (“ISF”), transfer of companies, donations and inheritance ;
  • Negotiation of "management packages”.

HIGHLIGHTS OF OUR EXPERIENCE

• Management of various tax audits and litigation for French companies and individuals:

  • Tax litigation: QPC in progress and appeal to the current State Council (20,000,000 € in base) ;

  • Contentious claim and appeal before the Administrative Court. (2.300.000 € in base) ;

  • Litigation for the recovery of a DTA in France by a foreign tax authority (€ 78,000,000 in fees) ;

  • Tax audit and hierarchical appeal against adjustments in France for oil activities abroad (€ 1,100,000 in base) ;

  • Tax audit and hierarchical appeal against VAT adjustments in France (€ 1,000,000 in fees) ;

  • Contentieux taxe de 3% devant le TGI de Nice ;

  • Tax assistance of foreign companies characterized by a permanent establishment in France (web companies, agents of players) ;

  • Several litigation against tax searches (L16B) ;

  • Contentious claims ;

  • Assisting verification (in progress) of several oil companies (English) for their operations in French-speaking Africa.

• Tax structuring of the interests of French client companies in Africa (Burkina Faso, Gabon, Ivory Coast, Senegal, South Africa, Uganda) and Asia (Vietnam). See the International Projects section ;
• Personal and inheritance tax strategy.