Tax law

Corporate taxation

Tax analysis of routine and exceptional transactions, drafting of technical memoranda, and optimisation of the tax burden in full compliance with applicable law.

Tax audits and tax litigation

Assistance during accounting audits and personal tax examinations. Preparation for meetings with the tax authorities, drafting of formal claims and representation before the administrative courts.

Personal taxation

• Preparation and optimisation of income tax returns
• Wealth taxation (IFI, the French real estate wealth tax, capital gains, rental income)
• Assistance with gifts and wealth transfers

Taxation of regulated professions

• Assistance with the preparation of tax returns
• Dealings with approved management associations
• Optimising the executive's remuneration

Cross-disciplinary audits

Working alongside our employment law, tax law and corporate law teams, we carry out cross-disciplinary audits to identify the legal, employment and tax risks within your structures. These audits are particularly recommended ahead of a sale or merger, or as part of a preventive compliance review.

International taxation for individuals

Advising executives and individuals on international mobility, from the analysis of tax residence through to the reporting obligations in each country concerned.

France-Switzerland taxation

• Transfer of residence, exit-tax deferral and choice of canton
• France-Switzerland successions since the end of the treaty in 2015
• Taxation of cross-border workers, the 2026 remote-work amendment and social security agreements

France-United States taxation

• FATCA, FBAR and reporting obligations to both tax authorities
• US trusts, IRA, 401(k) and RSUs for French tax residents
• Successions and gifts between France and the United States

International successions

• Determining the applicable tax rules
• Coordination with notaries and advisers in the other countries involved

International taxation — risk analysis and strategic support

• Carrying out risk reviews focused mainly on corporate income tax (CIT) issues, in particular in connection with intra-group financing transactions, the creation of foreign subsidiaries and general reviews of groups' tax positions.
• Supporting groups in their international expansion projects. For example, advising on the creation of a US subsidiary in order to identify the main tax issues linked to developing the American market and to define a remuneration model compliant with the arm's length principle.
• Analysing the financing arrangements of new entities (capitalisation, intra-group debt, etc.), drafting or reviewing the related contractual documentation and coordinating with foreign tax advisers.

Permanent establishment and withholding taxes

• Analysis of the risk of a permanent establishment being characterised in France or abroad in light of OECD principles and applicable international tax treaties.
• Analysis and securing of the treatment of withholding taxes (WHT) in France and abroad: tax qualification of the relevant income, verification of eligibility for treaty provisions, determination of the applicable rate, analysis of double-taxation relief mechanisms, and support with reporting and substantiation obligations.
• Determination of the French tax treatment of WHT levied abroad in breach of international tax treaties.

International coordination

• Coordination of projects involving several jurisdictions, in particular the creation of companies or establishments abroad and tax analyses requiring the involvement of foreign partner firms.
• Steering and coordinating analyses carried out by local tax teams, notably in Spain, Italy and Germany, to ensure the consistency of the tax positions adopted at group level.

Transfer pricing

• Active participation in the definition, implementation and review of the transfer pricing policies of international groups.
• Functional and economic analyses to determine the appropriate remuneration of the group's various entities in line with the arm's length principle.
• Active participation in the drafting of transfer pricing documentation, in particular Master Files, Local Files, technical memoranda and supporting analyses.

Tax audits and disputes

• Assistance during tax audits concerning transfer pricing, from the audit phase through to the preparation of hierarchical appeals.
• Assistance during tax audits relating to WHT, including review of the regularity of the procedure, monitoring of compliance with applicable deadlines, drafting of responses to the tax authorities and development of legal and tax arguments to defend the taxpayer's position.

Economic studies and case preparation

• Market studies and sector analyses to identify external economic factors likely to influence the activity or profitability of the companies analysed.
• Preparation of the lists of questions and document requests required to conduct the tax and economic analyses.