--- title: "Tax" id: "2037" type: "expertise" slug: "tax" published_at: "2026-01-26T09:02:33+00:00" modified_at: "2026-07-31T15:06:17+00:00" url: "https://www.august-debouzy.com/en/expertise/tax/" markdown_url: "https://www.august-debouzy.com/en/expertise/tax.md" excerpt: "Turning taxation into a strategic driver for your decisions Taxation has become a strategic battlefield. With constantly shifting regulations, expanding international frameworks, and growing compliance demands, every decision now carries long-term implications for a company’s sustainability. Tax risks are multiplying,..." taxonomy_language: - "English" taxonomy_post_translations: - "pll_69772da9b9f72" taxonomy_tax_expertise: - "Tax" taxonomy_tax_famille_expertise: - "Advisory" - "Transactional" --- ## Turning taxation *into a strategic driver for your decisions* Taxation has become a strategic battlefield. With constantly shifting regulations, expanding international frameworks, and growing compliance demands, every decision now carries long-term implications for a company’s sustainability. Tax risks are multiplying, audits are tightening, and litigation is becoming more complex. We turn this reality into a clear, actionable strategy. Our approach is built on anticipating risks, designing robust tax structures, and actively defending your interests before the authorities. Whether managing a cross-border transaction, structuring private wealth, or reorganizing a group, we combine high-level technical expertise with a deep understanding of business imperatives. Executives, investment funds, multinational groups, and family offices rely on our tailored support, from risk audits and cash flow optimization to dispute management and the structuring of their most sensitive operations. ## *our*Capabilities ### (01) Corporate Taxation Managing corporate tax requires constant vigilance in a rapidly evolving regulatory environment. We audit internal risks, assess the compliance of subcontractors, and review the reliability of tax IT systems. In acquisitions, our due diligence identifies potential exposures. We handle intragroup flows, transfer pricing, loss carryforwards, and thin capitalization issues. VAT, customs duties, R&D tax incentives, hybrid mismatch rules, DAC6, employee shareholding: every aspect is covered, in both domestic and international contexts. ### (02) Private Wealth Taxation Structuring the wealth of executives, managers, and private clients calls for a bespoke approach. We design tailored remuneration strategies, balancing salaries and dividends. IFI, gifts, and inheritance planning are optimized to ensure effective wealth transfer and preservation. We structure management packages such as free shares, BSPCEs, and performance shares, aligning fiscal efficiency with retention goals. Personal holding companies, trusts, fiduciary arrangements, and philanthropic projects through foundations or endowment funds complete our offering. ### (03) Financial Taxation Financial products, investment funds, and project financing instruments require sophisticated tax insight. Working closely with our corporate, private equity, and finance teams, we analyze the implications of each structure to design efficient, compliant, and high-performing solutions. This cross-functional collaboration enables us to anticipate friction points and adjust structures in real time. We make taxation a key lever in your investment decisions. ### (04) Transaction and Restructuring Taxation Every M&A, LBO, MBO, or divestment comes with significant tax implications. We conduct comprehensive due diligence and vendor due diligence, structure acquisitions and disposals, and coordinate group reorganizations in France and abroad. We assist foreign groups with their French investments and optimize share and asset sales as well as income distributions. Working hand in hand with our corporate and private equity teams, we ensure legal consistency and strategic alignment at every stage. ### (05) Real Estate Taxation Real estate assets require precise tax management throughout their lifecycle. We intervene from the earliest stages of acquisitions, performing pre-deal audits and structuring financing. Capital gains, rental income, SCI, SIIC, and OPCI taxation are optimized. Local taxes, real estate VAT, registration duties: every dimension is analyzed. For renovation projects, we activate the Malraux and historic monument regimes. Each operation is approached with a view to long-term value creation. ### (06) International Expansion Expanding internationally demands early anticipation of tax implications. We benchmark target countries’ tax frameworks, analyze France’s bilateral tax treaties, and guide you through the administrative steps of setting up subsidiaries. This approach ensures strategic decisions are informed by real opportunities, avoids double taxation, and delivers coherent and efficient international tax structures. ### (07) International Tax Strategy Global groups require coordinated and proactive tax management. We structure financial relationships between subsidiaries and parent entities, draft intragroup financing agreements, and manage approval processes. Intra-EU VAT, transfer pricing, restructuring: each lever is used to optimize global tax exposure. We also handle employee mobility, foreign asset acquisitions, and daily operational integration, transforming tax complexity into a competitive edge. ### (08) Tax Litigation We defend your interests before the tax authorities with determination. From risk assessments and mitigation strategies to support during audits, every step is designed to reduce exposure. Search and seizure proceedings, hierarchical appeals, pre-litigation discussions, representation before joint commissions, administrative and judicial courts: we deploy every available procedural tool. Our practice also covers computerized accounting disputes and criminal tax matters. Collective excellence at the service of the *highest standards.* Team [Philippe Lorentz ( Partner )](https://www.august-debouzy.com/en/collaborateur/philippe-lorentz/) [Xavier Rohmer ( Partner )](https://www.august-debouzy.com/en/collaborateur/xavier-rohmer/) [Elie Bétard ( Counsel )](https://www.august-debouzy.com/en/collaborateur/elie-betard/) [Jeanne Borde ( Associate )](https://www.august-debouzy.com/en/collaborateur/jeanne-borde/) [Vincent Fromholz ( Associate )](https://www.august-debouzy.com/en/collaborateur/vincent-fromholz/) [Théo Leclercq ( Associate )](https://www.august-debouzy.com/en/collaborateur/theo-leclercq/) [Théa Meunier ( Associate )](https://www.august-debouzy.com/en/collaborateur/thea-meunier/) Précédent Suivant ## Contact Us ## *our*References Tax #### French Media Group – Complex Tax Audit High-stakes tax audit and reassessment negotiation Represented independent French media group (revenue +EUR 150M) in high-stakes tax audit of subsidiary. Negotiation leading to significant reassessment reduction (+EUR 1M) and avoiding criminal referral. Tax-litigation coordination. Tax #### Coca-Cola France – QPC Sugar Tax QPC and constitutional aspects of sugar tax Advising Coca-Cola France on constitutional and tax issues related to proposed expansion of sugar-sweetened beverage tax. Legal and strategic input for potential QPC (priority constitutional question). Public affairs coordination. Tax #### Sia Partners – Blackstone Minority Investment Tax structuring of strategic investment Advising Sia Partners (leading global consulting firm in strategy and AI) and its founder on tax structuring of a strategic minority investment by Blackstone. Corporate and personal tax structuring, cross-border US coordination. *Rankings* & Recognitions m - (01)Best Lawyers 2027 – France Tax - (02)ITR World Tax 2026 – France General corporate tax - (03)ITR World Tax 2026 – France Transfer pricing [More distinctions](https://www.august-debouzy.com/en/distinctions/?search_tax-expertise%5B%5D=tax) ## *Latest* News [30/06/26 Deal 2 min August Debouzy advises Spacinov’s founding shareholders on Quilvest Capital Partners’ investment in Spacivox August Debouzy advised the founding shareholders of Spacinov, the French software company behind Spacivox, an omnichannel SaaS platform for B2C debt collection orchestration, on the investment by Quilvest Capital Partners as reference shareholder.](https://www.august-debouzy.com/en/deal/august-debouzy-advises-spacinovs-founding-shareholders-on-quilvest-capital-partners-investment-in-spacivox/) [29/08/25 Legal Article 6 min French Tax Authorities Release Draft Guidance on Management Packages On July 23, 2025, the French tax authorities released draft guidance clarifying the new tax regime for management packages (Article 163 bis H of the French Tax Code), detailing its scope, conditions, calculation method, and the allocation between capital gains and employment income.](https://www.august-debouzy.com/en/legal-article/french-tax-authorities-release-draft-guidance-on-management-packages/) [10/02/25 Legal Article 5 min Overview on the new social and tax regime introduced by the finance act for 2025 reminders Article 93 of the Finance Bill for 2025 was adopted on Thursday, February 6. This article provides for the introduction](https://www.august-debouzy.com/en/legal-article/overview-on-the-new-social-and-tax-regime-introduced-by-the-finance-act-for-2025/) [20/12/24 Legal Article 1 min August Debouzy Advises Trigano on the Acquisition of Bio Habitat August Debouzy has advised Trigano, a European leader in leisure equipment, on the acquisition of Bio Habitat, a subsidiary of Bénéteau, a specialist in mobile homes.](https://www.august-debouzy.com/en/legal-article/august-debouzy-advises-trigano-on-the-acquisition-of-bio-habitat/) [05/03/24 Legal Article 5 min Beyond the Olympic Games, France attracts large numbers of foreign athletes through a favourable impatriate tax regime At a time when the eyes of athletes all over the world are riveted on the Olympic Games, it is worth remembering that French tax legislation provides a ver](https://www.august-debouzy.com/en/legal-article/beyond-the-olympic-games-france-attracts-large-numbers-of-foreign-athletes-through-a-favourable-impatriate-tax-regime/) 01 05 Précédent Suivant [Find our latest news](https://www.august-debouzy.com/en/le-hub/) News ## *FAQ* ### (01) How does a law firm specializing in tax secure the structuring of your operations? Every operation (reorganization, merger, contribution, disposal, investment) has a tax dimension whose mastery determines legal certainty and financial predictability. The standard corporate income tax rate stands at 25% since 1 January 2022 (Article 219 of the French Tax Code), but applicable regimes vary depending on the nature of the transaction and the group structure. We audit tax risks, design structures that comply with applicable regulations and secure each stage of implementation. The objective is to ensure compliance while preserving the economic coherence of the project. ### (02) What tax issues govern the structuring of private or family wealth? Managing private wealth from a tax perspective requires coordinating income tax, capital gains, transfer duties and the real estate wealth tax within a constantly evolving regulatory framework. Article 964 of the French Tax Code subjects individuals whose net taxable real estate assets exceed EUR 1.3 million as of 1 January of the tax year to the IFI. We advise executives, family offices and private investors on compliant wealth structuring: transfers within the legal framework (Dutreil pacts, usufruct/bare ownership arrangements), patrimonial holding structures and classification of financial income. Each arrangement is designed to respect tax regulations while preserving long-term wealth. ### (03) How can you secure the tax treatment of a real estate transaction or international expansion project? Real estate transactions and international expansion projects generate complex tax issues: real estate VAT, registration duties, capital gains regimes, transfer pricing, bilateral tax treaties. Inappropriate tax treatment can result in reassessments, double taxation or disqualification of favourable regimes. We structure each operation by identifying applicable regimes, verifying eligibility conditions and anticipating areas likely to attract scrutiny. Our approach covers the entire cycle, from tax due diligence to post-acquisition compliance. ### (04) How can you anticipate the impact of the global minimum tax (Pillar 2) on your group? Directive (EU) 2022/2523, transposed into French law by the 2024 Finance Act (Article 33), establishes a minimum tax rate of 15% for groups with consolidated turnover reaching or exceeding EUR 750 million. This framework, applicable to fiscal years beginning on or after 1 January 2024, requires a comprehensive review of international structures. We advise multinational groups on assessing their exposure, adapting their structures to the new requirements and engaging with the relevant tax authorities. The goal is to ensure compliance while preserving the group’s operational coherence. ### (05) How can you defend your interests during a tax audit or dispute? A tax audit exposes the company to reassessments, penalties and reputational harm. Article L. 169 of the French Tax Procedures Code sets the statute of limitations at three years for direct taxes and VAT, extended to six years for undisclosed activities or serious failures. We defend clients at every stage: responding to proposed adjustments, hierarchical appeals, departmental commissions, contentious claims and representation before administrative and judicial courts. The objective is to contain exposure and secure the best possible outcome. ### (06) Why choose August Debouzy as your law firm for tax in France? Executives, investment funds, international groups and family offices entrust us with securing their tax positions and defending their interests before the tax authorities. We deploy high-level technical expertise combined with a deep understanding of business issues to structure operations in compliance, anticipate reassessment risks and manage disputes. Corporate tax, private wealth tax, financial tax, real estate tax, transactional tax, international tax and tax litigation: our integrated approach covers the full spectrum, from risk audits to dispute resolution.