Taxation - Asset Engineering

Corporate tax

  • Tax management of companies and groups of companies:
    • Assistance in the management of current tax issues related to corporate tax, VAT and local taxes
    • Assistance in the calculation of the tax result (yearly tax review)
    • Management of tax groups and inter-company transactions
  • Tax support for the realization of corporate finance and acquisition operations:
    • Restructuring operations (merger, partial merger, assets disposal), capital increase and reduction operations and sale / acquisition operations
    • Preliminary tax due diligence
    • Pre and post acquisition structuring – determination of the acquisition structure – financing of the acquisition
  • International taxation:
    • Tax issues related to inter-company transactions: withholding taxes, tax credits
    • Permanent establishment issues
    • Transfer of headquarters to France and overseas
  • Innovation tax:
    • R&D and innovation tax credits (« CIR » and « CII »)
    • Status of young innovative company (« JEI »)
    • « IP Box » tax regime applicable to incomes from patents and software

Taxation of executives and business owners and wealth management

  • Taxation of business owners and executives:
    • Legal and tax structuration of professional assets: holding setting-up, organization of corporate real estate, OBO
    • Definition of executive remuneration strategies
    • Definition and implementation of inheritance and donation strategies (Dutreil pacts, dismemberment of the ownership of shares, etc.…)
    • Transfer of tax residence to France or abroad
  • Taxation of managers
    • Advice on takeover projects, choice of the investment vehicle, transmission, international aspects
    • Advice on the implementation of managerial profit-sharing policies (free shares, business creator share subscription warrants, stock options)
  • Wealth taxation:
    • Wealth structuration and estate / donation tax planification
    • Tax regularization of assets held abroad
  • Real estate taxation:
    • Structuration of real estate investments: LMP/LMNP, SCI/SARL, holding, etc…
    • Assistance with real estate assets sale and transfer operations

Tax audits and litigation / relationships with the tax authorities

  • Tax assistance in the frame of tax audits at all stages of the procedure: answer to a tax reassessment notice, hierarchical appeal or before specific tax committees, drafting of administrative claims
  • Defense of the clients’ interests before administrative and judicial courts
  • Relationships with the tax administration: rulings, transactions, etc …

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