For several decades, France has applied a favorable tax regime to license income and capital gains from patents and some associated intangible assets. This system has been reformed in the 2018 Finance Bill to bring it into line with EU and OECD standards. It is now codified in Article 238 of the French General Tax Code, applicable to fiscal...Read
Taxation affects the lives of companies and individuals on a daily basis, and is an essential parameter of any strategic decision.
The “Tax law” department works with its clients in order to secure and optimise the tax management of their current or exceptional operations.
It also helps them with their relations with the tax department, and represents them before the courts in case of tax disputes.
It is most notably active in the following domains :
Corporate taxation :
- handling of recurring tax matters involved in corporate taxation (CT, VAT, local taxes),
- set-up and monitoring of a tax integration procedure,
- fiscal safeguarding and optimisation of operations including mergers-acquisitions, restructuring and corporate reorganisations,
- preparation of preventive audits or acquisition audits,
- set-up of incentive arrangements for directors and employees (stock options, BSCPE, AGA, “management package”),
- definition and safeguarding of the transfer price policy,
- set-up of French companies abroad, and foreign investments in FRANCE,
- requests for approvals and tax-related advance rulings,
- optimisation of tax credits (research tax credit, etc.),
- fiscal optimisation of transnational flows.
Wealth taxation :
- Taxation of earnings and property assets
- Transmissions & successions (national and international context)
- Transmissions of companies, notably in a family context
- Real estate taxation
- Tax audits regarding the fiscal structuring of property assets
- Income tax / wealth tax / IFI declarations for French residents and non-residents
- Delocalization, expatriation, impatriation
- Family governance,
- Leveraged family operations (OBO, FBO),
- Philanthropy within a context of asset structuring (endowment fund, French and foreign foundations, etc.)
- Regularisation of foreign assets
Pre-litigation & Disputes (regarding corporate taxation and wealth taxation) :
- assistance in the event of tax audits,
- negotiation and settlement with the tax department,
- preparation and drafting of complaints involving litigation,
- representation before all administrative or judicial authorities,
- disputes involving collections.
When performing its services, the department can naturally rely on support from the firm’s other areas of expertise (departments including “Corporate law – Mergers-acquisitions”, “Non-profit organisations and social entrepreneurship”, “Real estate law”, etc.), as well as a broad network of foreign correspondents.
Rankings of the department
- LEGAL 500 EMEA 2020, Tax, Tier 5/5
- LEGAL 500 Paris 2020 - Tier 5/5
- DÉCIDEURS 2019 - Financial and tax strategies
Asset taxation - Unbeatable 3/3
Research and innovation taxation & Research tax credit - Unbeatable 3/3
Financial transaction tax – Excellent 3/3
- Trophées du Droit 2020 : Corporate taxation – Bronze award
- Pierre GOUGÉ, Julien MONSENEGO, Séverine BRAVARD, Leslie D’ALASCIO, Anaïs FAURY, Clément GUITET, Edouard PIQUE
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