Taxation of companies, assets and non-profit organisations

Our team relies on a number of high value-added skills in corporate, personal and estate taxation to provide personalised support. The team assists our clients, whether legal entities or individuals, in developing a tax strategy, anticipating and managing tax audits, and all types of litigation. Our team offers a very wide range of services. We also work with other teams in the firm and an international network to structure your mergers, disposals, private equity and asset transactions

Areas of intervention

  • Daily assistance on French and international tax issues for companies of all sizes;
  • Acquisition audits for industrial and services or private equity clients;
  • Tax structuring of acquisitions, refinancing, disposals and mergers (audits, structure notes, securing legal documentation, etc.);
  • Reorganisation of national and international groups through mergers, takeovers, spin-offs, asset reallocations (validation of legal documentation, analysis of the impact of restructuring, preparation and follow-up of applications for approval and management of tax losses);
  • Setting up and annual monitoring of fiscally integrated groups (documentation of group formation and its evolution, review of integration files, management of tax deficits, in particular through the implementation of the extended base mechanism);
  • Assistance in the drafting of rescripts;
  • Assistance in the management of annual declarations (review of individual tax returns, production of withholding tax returns on all types of income, declaration of income from movable assets);
  • Assistance in obtaining and securing tax credits (CIR, CII, corporate sponsorship, etc.);
  • Taxation of real estate activities.

Employee share ownership and asset taxation

  • Implementation of management packages, profit-sharing plans and employee shareholding tools (plan and sub-plans of foreign free share plans, BSPCE, stock options)
  • Treatment of the tax implications of manager and employee mobility
  • Analysis of the structure of the manager's income
  • Wealth structuring in collaboration with qualified professionals (notaries, asset managers, banks, etc.)
  • Assistance with reporting obligations (income tax, IFI, real estate company reporting, 3% tax on real estate assets, manual donations. )
  • Advising the manager on the transfer of companies (in particular Dutreil pacts, future protection mandates) and real estate assets free of charge in France and abroad (inheritance and donation)
  • Tax analysis of the consequences of a business transfer for partners and managers and its tax optimisation
  • Tax management of real estate transactions

Assistance with tax audits and monitoring of tax disputes.

  • Advice on the tax strategy of the company or individual during the audit
  • Follow-up of the company in the audit phase
  • Drafting the taxpayer's defence
  • Representation of the taxpayer before the administration and the courts
  • Transaction support

Transfer pricing

  • Transfer pricing policy structuring;
  • Valuation of assets in the tax context (intra-group transfers, restructurings);
  • Definition of structuring schemes between related entities;
  • Development and implementation of transfer pricing policies and strategies;
  • Documentary construction, allowing the justification of policies according to French and international rules as well as compliance work (country-by-country reporting and simplified documentation);
  • Managing relations with the tax authorities in tax audit operations or international procedures (mutual agreement procedures or advance pricing agreements).
  • Advice on the preparation of transfer pricing declarations,

Advice on indirect taxation (VAT, CVAE, payroll taxes, C3S, indirect taxes, etc.),

  • Reviewing and securing the flow of goods and services with a supply chain process approach
  • Implementation of specific VAT regimes (real estate VAT, travel agents, finance and insurance, electronic invoicing. )
  • VAT / DEB / DES consistency review,
  • Securing taxpayers and partial taxpayers with regard to the right to deduct and payroll tax, in particular holding companies
  • Setting up VAT consolidation groups