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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