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Our Involvement
What Should You Expect from Your Tax Attorney?
Our role is, above all, to defend and protect your interests—whether in your business dealings, in your dealings with the tax authorities, or in your personal relationships.
In the context of your professional life, our mission is to provide you with the best possible guidance on the decisions you need to make and their tax implications, while respecting your strategic choices.
When dealing with the tax authorities, we protect you in the event that they challenge the choices and organizational structure adopted by your company—a situation that could have particularly serious consequences. Conversely, we assist our clients in bringing their tax affairs into compliance in order to minimize costs.
In family law matters, the tax attorney’s goal is to find a succession plan that respects the donor’s wishes and addresses all the requirements and challenges of the case.
In the context of your professional life, our mission is to provide you with the best possible guidance on the decisions you need to make and their tax implications, while respecting your strategic choices.
When dealing with the tax authorities, we protect you in the event that they challenge the choices and organizational structure adopted by your company—a situation that could have particularly serious consequences. Conversely, we assist our clients in bringing their tax affairs into compliance in order to minimize costs.
In family law matters, the tax attorney’s goal is to find a succession plan that respects the donor’s wishes and addresses all the requirements and challenges of the case.
How are cases handled?
Your case is handled by at least two partner attorneys. You are assured of having at least two points of contact who are thoroughly familiar with your case and capable of responding to your inquiries and making decisions.
After an initial consultation—whether in person or over the phone—we’ll work with you to identify the issues and determine the best strategy to follow.
One of the partners in charge of your case will handle the drafting of legal documents as well as correspondence with you and other parties involved. Internally, the partner may be assisted by an associate or a law clerk in training.
We are always available to our clients by phone and respond to your emails within 24 hours. Our clients never go without a response from their attorney.
After an initial consultation—whether in person or over the phone—we’ll work with you to identify the issues and determine the best strategy to follow.
One of the partners in charge of your case will handle the drafting of legal documents as well as correspondence with you and other parties involved. Internally, the partner may be assisted by an associate or a law clerk in training.
We are always available to our clients by phone and respond to your emails within 24 hours. Our clients never go without a response from their attorney.
How much does our service cost?
Generally speaking, there are three billing methods: hourly, flat-rate, or based on results.
There are situations in which it is impossible to know precisely in advance the scope and duration of the assignment, such as during tax audits, in the context of our involvement in negotiations or transactions, or as part of a tax advisory retainer. In such cases, we prefer to charge by the hour.
When the assignment is specific and quantifiable (drafting a memo, a policy document, or filing a litigation claim), we prefer to charge a flat fee and/or a percentage of the savings achieved.
Finally, in litigation matters (proposals for corrections, claims in dispute, briefs filed with the court, etc.), we charge contingency fees based on a percentage of the tax reductions or refunds obtained.
In any case, FareWell Tax determines its fees based on the value added by the service provided to our client. This way, you can be sure that our services will cost less than the savings you realize.
Our fees and payment terms are tailored to both the complexity of the case and the client’s circumstances.
There are situations in which it is impossible to know precisely in advance the scope and duration of the assignment, such as during tax audits, in the context of our involvement in negotiations or transactions, or as part of a tax advisory retainer. In such cases, we prefer to charge by the hour.
When the assignment is specific and quantifiable (drafting a memo, a policy document, or filing a litigation claim), we prefer to charge a flat fee and/or a percentage of the savings achieved.
Finally, in litigation matters (proposals for corrections, claims in dispute, briefs filed with the court, etc.), we charge contingency fees based on a percentage of the tax reductions or refunds obtained.
In any case, FareWell Tax determines its fees based on the value added by the service provided to our client. This way, you can be sure that our services will cost less than the savings you realize.
Our fees and payment terms are tailored to both the complexity of the case and the client’s circumstances.
Terms and Conditions of Service
To ensure transparency and predictability in our work, our firm’s policies and our relationships with clients are strictly governed by our General Terms and Conditions of Service.
View our General Terms and Conditions of Service (GTC)
View our General Terms and Conditions of Service (GTC)
Wealth Taxation
How can I pay less in taxes?
Taxes in France are primarily progressive: the more money you earn, the more taxes you pay. However, the applicable rates and cumulative taxation can result in effective tax rates that are virtually confiscatory.
The search for tax optimization depends on your compensation structure, your business structure, and the composition of your assets. A comprehensive assessment of your assets is essential to finding the best solution.
Taking advantage of “tax loopholes” can be a wise move, but they should be handled with caution.
The search for tax optimization depends on your compensation structure, your business structure, and the composition of your assets. A comprehensive assessment of your assets is essential to finding the best solution.
Taking advantage of “tax loopholes” can be a wise move, but they should be handled with caution.
How can you pass on your estate?
A successful transition requires careful planning and coordination in advance. The following questions should be addressed beforehand:
What should I give?
Who is it for?
How long will it take?
Optimizing the transfer of family assets requires advance planning. There are many solutions available to address your specific needs precisely and effectively, such as the division of property, the use of unincorporated partnerships, life insurance, cash settlements, and so on.
When it comes to the transfer of corporate securities, the legal framework of the “Dutreil Pact” is extremely effective at reducing the total cost of gift taxes, provided that the requirements of this framework are properly understood.
What should I give?
Who is it for?
How long will it take?
Optimizing the transfer of family assets requires advance planning. There are many solutions available to address your specific needs precisely and effectively, such as the division of property, the use of unincorporated partnerships, life insurance, cash settlements, and so on.
When it comes to the transfer of corporate securities, the legal framework of the “Dutreil Pact” is extremely effective at reducing the total cost of gift taxes, provided that the requirements of this framework are properly understood.
How should you manage the tax aspects of your assets?
In general, assets can be grouped into three main categories:
The business tool (your company or your companies' securities)
Real estate assets (primary residence, investment properties, securities of companies primarily engaged in real estate)
Personal assets (financial investments, life insurance, employee savings plans, works of art and valuable items, etc.)
Your assets may be located in France and/or abroad; these assets may be held in your sole name, jointly with your spouse, or as co-owned property, as well as in full ownership or under a split ownership arrangement (usufruct or bare ownership).
The tax management of your assets must, above all, address legal and economic issues (management authority, financing needs to maintain your standard of living, savings capacity, short- and long-term goals, planning for a potential transfer of assets, etc.).
Once your goals have been established, our job will be to implement the tax solutions best suited to your situation (marital property regime, use of a civil management company, adjustments to your investment budgets, etc.).
The business tool (your company or your companies' securities)
Real estate assets (primary residence, investment properties, securities of companies primarily engaged in real estate)
Personal assets (financial investments, life insurance, employee savings plans, works of art and valuable items, etc.)
Your assets may be located in France and/or abroad; these assets may be held in your sole name, jointly with your spouse, or as co-owned property, as well as in full ownership or under a split ownership arrangement (usufruct or bare ownership).
The tax management of your assets must, above all, address legal and economic issues (management authority, financing needs to maintain your standard of living, savings capacity, short- and long-term goals, planning for a potential transfer of assets, etc.).
Once your goals have been established, our job will be to implement the tax solutions best suited to your situation (marital property regime, use of a civil management company, adjustments to your investment budgets, etc.).
Corporate Taxation
How much will my restructuring cost me?
In France, there are numerous preferential tax regimes, which are granted either by law or upon approval.
We have tools available to make restructuring your company or group easier—and much less expensive. But keep in mind that no single tax “formula” applies as is; you need to be creative and realistic.
We have tools available to make restructuring your company or group easier—and much less expensive. But keep in mind that no single tax “formula” applies as is; you need to be creative and realistic.
How Should You Manage Your Business from a Tax Perspective?
Effective tax management is that which ensures legal certainty and tax optimization.
This balance can pose challenges, particularly due to recurring changes in legislation, which can sometimes create a risk for the company and at other times lead to cost savings.
We believe that tax optimization does not pose a risk as long as it is properly implemented and meets an economic or legal need of the company.
A regular audit of your company’s tax situation, conducted jointly by your tax attorney and your certified public accountant, will help you avoid overtaxation while protecting your company in the event of a tax audit.
This balance can pose challenges, particularly due to recurring changes in legislation, which can sometimes create a risk for the company and at other times lead to cost savings.
We believe that tax optimization does not pose a risk as long as it is properly implemented and meets an economic or legal need of the company.
A regular audit of your company’s tax situation, conducted jointly by your tax attorney and your certified public accountant, will help you avoid overtaxation while protecting your company in the event of a tax audit.
How can I retain key employees in my company?
Many tools—some better known to the general public than others—already exist: stock options, bonus shares, BSPCE, preferred stock, management companies, etc. However, the key word is always “tailor-made.”
Here again, we find the most suitable approach to incentivize “rising stars” or proven key managers to focus on results or take an equity stake in the company. We work with both established companies and startups.
Here again, we find the most suitable approach to incentivize “rising stars” or proven key managers to focus on results or take an equity stake in the company. We work with both established companies and startups.
How can payroll taxes be reduced in holding companies?
The primary purpose of a holding company is to manage the equity interests of its subsidiaries. It may also provide technical services to its subsidiaries, including legal, administrative, and financial services.
In this case, the company is subject to VAT only on its technical services. The remainder of its revenue comes from services that are outside the scope of VAT.
If revenue excluding VAT accounts for at least 10% of total revenue, the company will be liable for payroll tax. This tax, ranging from 4.25% to 13.60% of gross wages, applies to the wages of company employees who work exclusively in the financial sector (investment management) or in both the commercial sector (technical services) and the financial sector. These individuals are most often executives and accounting department staff.
To reduce payroll tax costs, it is possible to create separate commercial and financial sectors and assign employees to each sector.
This optimization must be developed in a structured and precise manner. We assist you in establishing these divisions and making decisions regarding the assignment of the company’s employees, as well as in putting in place evidence that is sufficiently admissible before the tax authorities.
In this case, the company is subject to VAT only on its technical services. The remainder of its revenue comes from services that are outside the scope of VAT.
If revenue excluding VAT accounts for at least 10% of total revenue, the company will be liable for payroll tax. This tax, ranging from 4.25% to 13.60% of gross wages, applies to the wages of company employees who work exclusively in the financial sector (investment management) or in both the commercial sector (technical services) and the financial sector. These individuals are most often executives and accounting department staff.
To reduce payroll tax costs, it is possible to create separate commercial and financial sectors and assign employees to each sector.
This optimization must be developed in a structured and precise manner. We assist you in establishing these divisions and making decisions regarding the assignment of the company’s employees, as well as in putting in place evidence that is sufficiently admissible before the tax authorities.
Tax Litigation
In the event of a tax audit of a company, how should the executive respond?
In the course of their professional career, it is very likely that a business leader will face a tax audit at least once. In most cases, they have little or no knowledge of their rights regarding tax audits, particularly in the event of a tax search.
Furthermore, the executive is not made aware of the risk involved and does not know how to respond when the auditors arrive.
However, inappropriate behavior caused by stress, panic, fear, or a lack of legal knowledge can have detrimental consequences for the audit, and it will then be difficult to reverse course.
We're here to help you prepare for these types of situations and navigate tax audits with greater peace of mind.
Furthermore, the executive is not made aware of the risk involved and does not know how to respond when the auditors arrive.
However, inappropriate behavior caused by stress, panic, fear, or a lack of legal knowledge can have detrimental consequences for the audit, and it will then be difficult to reverse course.
We're here to help you prepare for these types of situations and navigate tax audits with greater peace of mind.
What are the main deadlines for filing with the tax authorities?
The tax authority has a certain period of time to correct omissions, deficiencies, inaccuracies, or errors in tax assessments (“correction period”), regardless of whether these errors were committed by the taxpayer or by the tax authority itself.
In principle, the carryover period is 6 years, but generally speaking, this period most often expires on December 31 of the third year for which the tax is due; for example:
Taxes due on 2023 income (tax returns filed in the spring of 2024) will become time-barred on December 31, 20224.
The corporate income tax due for the fiscal year ending December 31, 2023, will become time-barred on December 31, 2024.
These time limits may be extended if no declaration has been filed or if the declaration is incomplete. For example, if a foreign account is not declared, the statute of limitations is 10 years!
With regard to local taxes, the statute of limitations is shorter and expires on December 31 of the second year for which the tax is due.
In principle, the carryover period is 6 years, but generally speaking, this period most often expires on December 31 of the third year for which the tax is due; for example:
Taxes due on 2023 income (tax returns filed in the spring of 2024) will become time-barred on December 31, 20224.
The corporate income tax due for the fiscal year ending December 31, 2023, will become time-barred on December 31, 2024.
These time limits may be extended if no declaration has been filed or if the declaration is incomplete. For example, if a foreign account is not declared, the statute of limitations is 10 years!
With regard to local taxes, the statute of limitations is shorter and expires on December 31 of the second year for which the tax is due.
Can a tax law that violates the Constitution be struck down?
The Priority Question of Constitutionality (QPC) allows an individual to ask the Constitutional Council to determine whether a legislative provision that has already been enacted is unconstitutional.
Indeed, while paying taxes is a civic duty, the assessment of taxes is also governed by constitutionally enshrined principles, namely the principle of equality before the tax system, the freedom to engage in business, and the right to property.
Our job is to determine whether the application of tax legislation would result in a violation of our clients’ fundamental rights.
We have already identified several questions to raise, particularly regarding the office tax in the Île-de-France region.
Indeed, while paying taxes is a civic duty, the assessment of taxes is also governed by constitutionally enshrined principles, namely the principle of equality before the tax system, the freedom to engage in business, and the right to property.
Our job is to determine whether the application of tax legislation would result in a violation of our clients’ fundamental rights.
We have already identified several questions to raise, particularly regarding the office tax in the Île-de-France region.
Local Taxation
How can the office tax in Île-de-France (TSB) be reduced?
The TSB is a tax levied on items necessary for office, commercial, and storage activities in Paris and the Île-de-France region. This tax increases every year and places a significant burden on companies' budgets.
A legal and tax analysis of the property category can be an effective way to optimize the TSB.
For example, premises rented as offices may be considered commercial premises for the purposes of calculating the office tax. If these premises are located in the 8th arrondissement of Paris, this classification process may result in an exemption or a reduction of approximately 70% in the tax.
A detailed analysis of the floor space and use of your premises can also help you save money. In fact, certain areas are exempt from the tax and therefore do not need to be included in the tax calculation.
A legal and tax analysis of the property category can be an effective way to optimize the TSB.
For example, premises rented as offices may be considered commercial premises for the purposes of calculating the office tax. If these premises are located in the 8th arrondissement of Paris, this classification process may result in an exemption or a reduction of approximately 70% in the tax.
A detailed analysis of the floor space and use of your premises can also help you save money. In fact, certain areas are exempt from the tax and therefore do not need to be included in the tax calculation.
How can I minimize my property tax?
Property tax is a tax payable annually by the owner or beneficial owner of a property, based on its assessed rental value. The property may be either vacant land or a developed property.
In addition to seeking exemptions, owners and beneficial owners of commercial properties can reduce the cost of this tax by optimizing the assessed rental value on which the property tax is based.
To optimize your property tax base, we assist you in reporting your properties and their characteristics, as well as in challenging, if necessary, the rates set by the department and applicable to your property.
An audit of your situation makes it possible to identify instances of overtaxation, in particular by comparing the classification and characteristics (tax rate, location coefficient, flat-rate assessment, smoothing, etc.) of your premises with the comparables used by the tax authorities.
In addition to seeking exemptions, owners and beneficial owners of commercial properties can reduce the cost of this tax by optimizing the assessed rental value on which the property tax is based.
To optimize your property tax base, we assist you in reporting your properties and their characteristics, as well as in challenging, if necessary, the rates set by the department and applicable to your property.
An audit of your situation makes it possible to identify instances of overtaxation, in particular by comparing the classification and characteristics (tax rate, location coefficient, flat-rate assessment, smoothing, etc.) of your premises with the comparables used by the tax authorities.
Do you have another question?
Do you have a question that isn’t answered here? Contact us!
We will respond as soon as possible.
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