Tax

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.

Structuring the wealth of executives, managers, and private clients calls for a bespoke approach. We design tailored remuneration strategies, balancing salaries and dividends. ISF, 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.

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.

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.

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.

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.

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.

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.