1 Tax law
Our main assignments are the following :
- Company tax review : reviewing or calculating taxable income, calculating and securing tax credits or reductions (CIR research tax credits, CICE competitiveness and employment tax credits…), deductibility status of provisions
- VAT audit : analysing intra-EU VAT territoriality rules, reviewing mandatory statements on invoices
- Setting up and documentation of reliable audit trails (PAF)
- Fiscal representation in matters of VAT
- Tax consolidation assistance: assignments regularly carried out for our clients include monitoring current consolidation requirements, from a group’s initial constitution to specific annual returns and providing assistance to tax consolidated groups in complex operations such as mergers or acquisitions of other tax consolidated groups and refinancing operations;
- Consulting on technical and complex matters : thin capitalization rules, breakdown between land and buildings for amortization purposes, VAT status of subsidies, calculating the tax base for tax on salaries with regard to directors’ transverse duties, characterization and repercussions of a change in business activity on tax loss carryforward ;
- Restructuring assistance (merger, asset transfer, spin-off, change in business activity) : structuring analysis to establish feasibility and optimal arrangement for the intended operation, requesting approval for the transfer of losses, completing post-merger formalities.
2 Assistance with tax audits and litigation
- Assistance during inspection of the accounts : participating in meetings (in particular wrap-up meetings) with the inspector, assisting with preparing the documents to be communicated and answers to be provided ;
- Post-inspection assistance : drawing up responses to reassessment proposals, support in the event of an appeal to a higher authority or before commissions, negotiating with the tax authorities with a view to a settlement ;
- Assistance with claims before the Courts : drafting claims, bringing cases before the competent court and drafting statements;
- Monitoring domestic and European case law : filing claims before the court in order to obtain refunds of income tax or other taxes non-compliant with constitutional principles or European directives.
3 International business and personal taxation
- Consulting on technical and complex subjects : permanent establishment issues, taxation methods for different flows under bilateral tax treaties (licence fees, dividends, interest…), questions on withholding taxes and tax credits;
- Establishing or reviewing transfer price-related documentation : functional analysis, drafting of master file or local file, comparable analysis with the help of a partner financial analysis firm, simplified annual TP returns;
- Assistance with international mobility : submitting impatriate and expatriate staff declarations, advise on qualifying stock option or share incentive plans under French favourable regimes.
4 Local taxation
- Tax base review and optimization for business property contributions (CFE);
- Assistance with business added-value contribution (CVAE), in particular declarations: calculating and submitting requests for ceilings on contributions depending on the added value;
5 Personal and asset taxation
- Consulting on personal income tax (IR) matters : establishing taxpayer’s residence for tax purposes, advice on personal tax withheld at source;
- Consulting on real estate wealth tax (IFI) matters : rules applicable to real estate companies, issues raised by indirect control of companies;
- Business transfer structuring and assistance : calculating and establishing tax arrangements for added value, tax rollovers, tax deferment for transfers, specific tax abatement schemes, anticipating tax-related issues involving the creation of holdings for takeovers…
- Drawing up of “Dutreil” agreements.
6 Miscellaneous taxation
- Consulting on technical and complex subjects : establishing liability or otherwise for taxes such as the 3% tax assessed on the market value of real properties help by foreign companies or the specific tax on advertising expenses…;
- Assessment of liability for business taxes for associations or other non-profit organizations.