Tax
Our tax department offers a full-service tax practice, assisting clients in matters involving:
- Share acquisitions or sales, mainly for industrial or operational clients but also in the context of LBOs (structuring, tax audits, reps and warranties, tax consolidation, thin capitalization, holding companies, etc.);
- Mergers, contributions of assets, demergers and other group reorganizations;
- Structuring commercial transactions and inbound and outbound profit flows (dividends, interest, royalties) notably in cross-border transactions (withholding taxes, transfer pricing, permanent establishments, VAT);
- International employees and management mobility (tax residence, expatriation, impatriation) and employee compensation schemes (management packages, stock options, free shares or similar instruments);
- Real estate investments in France realized by non-French tax residents, including through special purpose civil-law entities (SCIs);
- Personal asset reorganizations and tax planning (donations, wealth tax, etc.);
- Tax treatment of not-for-profit organizations (associations, foundations or fonds de dotation) and tax analysis of foreign entities (trusts or Dutch stichtings);
- Relationship with the tax authorities (tax audits, litigation, rulings, administrative approvals) and litigations before French courts.