Tax law
Corporate taxation, transactional taxation and M&A
- Determination of taxable income; review of tax returns
- Companies’ groups (tax consolidation, intra-group services, treasury agreements, loan declarations, parent-subsidiary regime, investments)
- Taxation linked to the setting-up and sale of companies
- Tax structuring of French and cross-border restructuring operations
- Tax audits (BDD, VDD, and internal tax audits) and review of tax guarantee clauses
- Ruling applications (transfer of losses, preferential tax treatment)
International
tax support
- Analysis of international tax treaties (direct taxes and inheritance/donation); determination of withholding taxes and imputation of tax credits
- Analysis of permanent establishment risk
- Anticipation of transfer pricing issues
- DAC6 reporting obligations
- Cross-border reorganizations
- International mobility (employees seconded abroad, impatriate status, exit tax)
- Coordination with local advisors
- Monthly declarations of foreign-source income (Form n°2778)
Personal and estate taxation (residents/ non residents)
- Asset taxation (residents/non-residents)
- Structuring schemes (holding companies, transfer of assets)
- Ownership stripping (bare ownership, usufruct)
- Optimizing remuneration
- Tax residency
- Inheritance and transfer (gifts, Dutreil)
- Personal Income tax
- Property wealth tax
- Trusts
- Disclosure of foreign accounts; regularization of tax returns
Real estate taxation
- Real estate taxation
- Capital gains of professionals and individuals
- Real estate VAT (acquisition/sale, VAT deduction)
- Registration fees (commitment to build, commitment to resell)
- Furnished rentals (LMNP, LMP, para-hotel)
- 3% tax
- Taxation of property dealers
- Tax reduction schemes
- Office tax
- Business property tax “CFE” and property taxes
Tax litigations and audits
- Requests for tax rulings
- Preparation of tax claims
- Assistance with tax audits
- Litigation before the tax judge