Tax Law

Tax law requires specialized knowledge, due to the ever-growing body of tax legislation, regulation, international conventions, and accepted principles.  

To provide you with the most relevant advice and tailored service, our tax law team draws on corporate, personal, and wealth taxation, to help all clients develop tax strategies, anticipate and manage tax audits, and handle any type of tax dispute. 

Our tax lawyers also structure your mergers, acquisitions, private equity and estate planning transactions, with the assistance of other teams within the firm and our international partners network.  

Corporate taxation

We surround your business with the best specialists to secure and optimize all aspects of tax issues, nationally and internationally, including: 

• .Internal tax risk and subcontractor compliance audits 
• Tax software audit 
• Acquisition audit and due diligence 
• Management of intragroup flows and transfer pricing 
• Management of tax losses 
• Management of under-capitalization issues 
• National and Community VAT 
• Customs issues related to your operations (applicable tariffs, customs value) 
• R&D taxation (intellectual and industrial property, R&D tax credit...) 
• Compliance audit (hybrid directive, DAC6...) 
• Employee share ownership 

Wealth and Asset Taxation

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

• Remuneration structures (salary vs dividends) 
• Wealth structures (wealth tax, gifts, inheritances) 
• Management packages (stock options, free shares, performance shares) 
• Personal holdings 
• Trusts and fiduciaries (declarative obligations) 
• Philanthropy (foundations, endowment funds) in matters of estate taxation 

Financial Taxation

With our Corporate, Private Equity and Financing teams, we provide leading expertise on the taxation of financial products, investment funds, and financing instruments. 

Transaction and Restructuring Taxation

We cover all tax issues related to your national and international transactions (M&A, LBO, MBO, sales, restructuring...), including: 

•  Acquisition or sale audits (due diligence and VDD) 
• Transactions structuring 
• Internal reorganizations, in France and abroad 
• French investment structuring 
• Assets and securities sale of securities optimization
• Income distribution optimization (dividends, interest, royalties). 

Property taxation

We guide you at every stage of your real estate projects, including with: 

• Acquisitions Pre-transaction audits 
• Project financing 
• Capital gains and rental income taxation 
• SCI, SIIC, OPCI taxation 
• Local taxation (CET, property taxes, office taxes...) 
• Real estate VAT, registration fees, taxes on profits from property dealers 
• Renovation (specific regimes for Malraux and historic monument properties) 

Expansion

Tax is a key factor in determining the best course of action for expanding internationally. Our team supports you in developing your expansion strategy by benchmarking the tax frameworks of target countries, conducting a comprehensive analysis of relevant tax agreements, and assisting with all administrative procedures to finalize your set up abroad. We enable your global expansion while minimizing your tax exposure. 

International Tax Strategy

We work with leading multinational corporations to manage and optimize their international tax accounts, in particular: 

• Structuring financial relationships with subsidiaries 
• Intra-group financing agreements 
• Management of intra-community VAT 
• Determination of transfer pricing 
• Restructuration tax implications 
• Tax burden optimization, financing, and debt management 
• Day-to-day tax management (integration, taxes, etc.) 
• International employee mobility 
• Acquisition of assets abroad 

Tax litigation

We offer comprehensive tax audit support to help you identify and minimize your tax risks. We provide strategic advice on risk mitigation, assist with tax audits, and draft responses to tax authorities, helping you seek amicable solutions and provide representation in both administrative and judicial courts. And we do so internationally, for a variety of services, including: 

• Corporate and individual tax audit assistance; 
• Tax procedure (visits and seizures); 
• Pre-litigation assistance (hierarchical recourse and interaction); 
• Assistance before the joint TCA and direct taxes committees; 
• Assistance before first instance and appellate courts; 
• Assistance in specific matters relating to computerized accounting control; 
• Assistance in tax criminal law matters.