Review of tax issues

Your issues
Each day, you make decisions that have tax consequences.
Have you properly assessed the situation?
Have you made the right choices? Do you think you have correctly evaluated the risks your business faces?

Our solutions:
The review provides a complete analysis of your tax situation, identifies existing or underlying problems and offers appropriate solutions.
The firm will assist you in implementing the recommendations and monitoring them.

► Tax study: a multi-tax approach: corporate tax, local taxes, value added tax (VAT), etc., tax benefits: tax credits, etc.

► Legal study:general meetings, agreements, service contracts, loans, guarantees, etc.

 Study of internal financial flows, indebtedness, profitability, transfer pricing issues, group cash management agreements, etc.

 Revisions to tax returns, articles of association, registration certificates, agreements, general meetings, etc.

Tax audits and tax litigation

Your issues:
Your company is subject to an accounting audit and a tax audit.
You must respond to the tax authorities’ requests.

Our solutions:
Our firm assists and represents your company in all tax proceedings.

► Advice during the tax audit, discussions with the tax authorities

Response to an adjustment proposals, meetings with the Principal Tax Inspector, before the departmental tax commission, referral before the departmental ombudsman, tax claims, Settlement

► Referral before the administrative and judicial courts, then, if necessary, referral before the administrative and judicial courts of appeal, Oversight and assistance before the Conseil d’Etat and the Court of Cassation

► Suspension of payments and setting up guarantees, Set-offs, Settlement of penalties

International Tax

Your issues
Your company does business both in France and abroad. To determine the amount of profits taxable in either jurisdiction, you must take into account international tax treaties, transfer pricing issues, etc.

Our solutions:
The firm will assist you in understanding and applying the relevant international tax treaties and in analysing transfer pricing issues.

► Determining if a taxable activity is conducted in a foreign country and in France

► Presence of a permanent establishment in accordance with the criteria under the treaties

► Identifying cases in which foreign companies are subject to corporate tax in France

► Study of prices charged in intragroup transactions (transfer prices)

► Analysis of transfer pricing methods

 Documentation for transfer prices in accordance with legal requirements

Restructurings, mergers & acquisitions

Your issues:
You have questions about your company’s strategies for developing and adapting to change.

Our solutions:
In this type of matter, the firm assists you in making the right choices under the tax laws, the corporate law and when raising funds.

► Creation, acquisitions and takeovers of companies.

► Mergers, contributions of securities, contributions of assets, demergers, sales of companies, start-ups, holding companies, etc.

► Choice of structure: limited liability company, simplified limited company, etc.

► Business transfers: retirement of executives, etc.

► Advice in connection with raising funds for creation of a company, capital increases, etc