Your questions

Our role is primarily to defend and protect your interests in your business dealings, in dealings with the tax authorities and in your personal life. 

We strive to advise our clients on their business decisions and the associated tax consequences, while respecting their strategic decisions. 

In dealings with the tax authorities, we will protect you should the authorities challenge your decisions and the organisational structure of your company, which can have significant consequences. We also help our clients regularise their tax position in order to limit costs. 

In terms of family matters, tax lawyers aim to find an appropriate transfer solution for the donor, giving due consideration to demands and issues.

Your matter will be handled by at least two partners, thus ensuring that you have at least two contacts who fully understand your issue and who are able to respond and make decisions. 

Once we have discussed matters with you either in person or over the phone, we will liaise with you in order to establish the issues involved and propose a strategy.

One of our partners will be responsible for drafting documents and for corresponding with you and the other people involved. He or she may be assisted in-house by an associate or trainee lawyer. 

We are always available to discuss matters with our clients over the phone and reply to e-mails within 24 hours. Our clients will always hear back from us.

Generally, we invoice our services in one of three ways: hourly, as a flat fee or as a success fee.

It can be impossible to accurately determine the resources and time needed to complete an assignment, particularly in the context of a tax audit, if we are involved in negotiations or a settlement on your behalf or in the context of a lump-sum assessment. We usually invoice such matters on an hourly basis. 

For assignments that are specific and quantifiable (drafting of memos, structure memos, filing of a litigation claim), we tend to charge a flat fee and/or a percentage of the saving made. 

For litigation matters (proposed tax reassessment, litigation claim, filing of submissions in court, etc.), we charge a percentage of the amount cancelled or refunded, as a success fee.

We invariably set our fees according to the value added of the service we provide to our client. You can therefore rest assured that our service will not cost as much as the saving you make. 

Our fees and payment methods vary according to your circumstances and the complexity of the matter we are dealing with.

If you have further questions about our services, feel free to contact us !
We will get back to you as soon as possible.

Our relationship with our clients is based on honesty, accuracy and transparency in order to build solid relations and mutual trust.

The firm’s policy and relations with our clients are strictly governed by our General Terms and Conditions of Services “GT&C”.

General Terms and Conditions of Service

Taxes in France usually increase according to your income. However, tax rates and the number of taxes imposed upon you can lead to exorbitant tax rates.

Tax optimisation solutions depend on how you generate income, your business structure and your assets, and we must therefore analyse your assets in order to identify the best solution.

It can be shrewd to use ‘tax loopholes’, although it is important to be careful when doing so.

Generally, assets can be categorised into three groups:

• Business assets (your company or your companies’ securities)
• Property (main home, investment properties, securities of real estate companies)
• Movable assets (financial investments, life insurance, employee savings, works of art and valuables, etc.)

Your assets may be situated in France and/or another country and may be owned outright by you, jointly with your spouse, in common, or on a freehold or subdivided basis (beneficial ownership or legal ownership).

Your assets must be managed from a tax perspective according to the associated legal and economic issues (management authority, financing requirements to guarantee your lifestyle, savings capacity, short- and long-term objectives, proposed transfers, etc.).

Once your objectives have been established, we will implement tax solutions that are most suited to your circumstances (matrimonial property regime, use of a non-commercial management company, budget changes for your investments, etc.).

A successful asset transfer requires a lot of forward planning and discussion, and it is advisable to consider the following beforehand:

• What do you wish to transfer?
• To whom?
• When?

An optimal asset transfer requires forward planning. There are numerous ways of effectively transferring your assets, for example by subdividing ownership, using a non-commercial company, life insurance, balancing payments, etc.

In terms of transfers of equity interests, the statutory ‘Pacte Dutreil’ mechanism is extremely effective for reducing the burden of gift tax, providing that due consideration is given to the constraints associated with this mechanism. 

If you have further questions about our services, feel free to contact us !
We will get back to you as soon as possible.

France has various preferential tax regimes in place, which apply either by law or by approval.

We have tools at our disposal to ensure that your company or group restructuring is a more straightforward and much less costly process.

However, there is no tax ‘blueprint’ as such; a restructuring requires imagination and pragmatism.

Effective tax management is key to guaranteeing legal security and tax optimisation.

It can be difficult to establish this balance due to recurring legislative amendments which, although risky for companies, also result in savings. 

We do not believe that tax optimisation is a factor of insecurity, providing that it is correctly implemented and fulfils a company’s economic or legal requirements. 

By arranging for your tax lawyer and accountant to regularly audit your company’s tax position, you will avoid overpaying tax and will protect your company in case of an audit by the tax authorities.

There are many ways to retain your employees, some of which are better known than others: stock options, free shares (eg restricted stock units), founder warrants, preference shares, ManCos, etc.

However, we pride ourselves on always delivering a tailored service, and will therefore identify the most appropriate profit-sharing mechanism for employees, from ‘new talent’ to established key managers.

We provide services to both established groups and start-ups.

If you have further questions about our services, feel free to contact us !
We will get back to you as soon as possible.

Managers are likely to be involved in at least one tax audit during their career. In the majority of cases, managers have little or no knowledge of their rights in the event of a tax audit or premises search. In addition, they are unaware of the risks involved and do not know what to do when an auditor turns up. 

Acting inappropriately due to stress, panic, fear or lack of legal knowledge can adversely affect an audit, making it difficult to backtrack. 

We can work with you to help you anticipate this kind of situation and remain calm in the event of a tax audit.

The tax authorities have a period (known as the ‘délai de reprise’, or correction period) in which they can correct omissions, deficiencies, inaccuracies or tax errors committed by the taxpayer or the authorities themselves. 

In principle, the authorities have a correction period of 6 years, although it usually expires on 31 December of the third year for which the tax is due. For example:

• The correction period for tax due on income generated in 2019 (for tax returns filed in the spring of 2020) will expire on 31 December 2022.
  
• The correction period for corporation tax due for the year ended 31 December 2019 will expire on 31 December 2022.

These time limits may be increased if no tax return is filed or if a tax return is incomplete. For example, action against a person who fails to declare an account in another country must be taken within 10 years! 

The correction period for local taxes is shorter and expires on 31 December of the second year for which the tax is due.

An application for a priority preliminary ruling on the conformity of a legislative provision with the Constitution (QPC) is an application to the Constitutional Council to check whether a legislative provision that has already come into force is unconstitutional. 

Although paying tax is a civic duty, taxes are calculated in accordance with constitutional rules, including the principle of tax equality, entrepreneurial freedom and the right to own property.

We check whether enforcing a piece of tax legislation would breach the fundamental rights of our clients.

We have already determined several questions that can be asked, particularly with regard to the tax on offices in the Ile-de-France region.

If you have further questions about our services, feel free to contact us !
We will get back to you as soon as possible.

The TSB is levied on office, business and storage premises in Paris and the Ile-de-France region. It increases each year and has a significant impact on company budgets. 

A legal and tax analysis of your premises can be a great solution to paying less tax.

For example, office premises can be deemed business premises for the purpose of calculating office tax. Categorising premises in the 8th district of Paris can result in an exemption or tax reduction of around 70%.

Savings can also be made by accurately analysing your premises and the purpose for which they are used. Some premises are tax-exempt and must therefore be disregarded when calculating the amount of tax due.

Property tax is due each year by the owner or beneficial owner of a property and is based on the property’s rental value according to the Land Registry. The property may be a plot of land or a building. 

In addition to identifying exemption scenarios, owners/beneficial owners of business premises can reduce their liability for property tax by optimising the rental value of their property on which the tax is levied. 

In order to optimise the tax base according to which your property tax is calculated, we can help you to complete your property tax returns, establish the characteristics of your property and, if necessary, dispute the taxes levied by the tax authorities on your property.

We can audit your position to ensure that you are not being overtaxed, including by establishing the category and legal definition of your premises (rate, location coefficient, limitation of variations in rental value (planchonnement), gradual inclusion of revised rental value in local taxes (lissage), etc.) compared to the comparisons used by the tax authorities.

The main purpose of a holding company is to manage its subsidiaries’ equity interests. The company may also provide specific services to its subsidiaries, such as legal, administrative and/or financial services.

Such companies are only liable for VAT on the specific services they provide. Their remaining turnover is generated through services that are VAT-exempt.

If a company’s turnover excluding VAT accounts for 10% or more of its total turnover, the company will be liable for payroll tax. This tax, which varies between 4.25% and 13.60% of a person’s gross salary, is levied on the salaries of staff who work solely in the financial sector (management of equity interests), the commercial sector (specialist services) and the financial sector. These people are usually managers and accounting staff. 

In order to reduce the burden of payroll tax, employees can be categorised according to whether they work in the commercial sector or the financial sector. 

It is crucial that this form of tax optimisation is managed carefully and precisely. We can help you to define these sectors, decide how your employees should be categorised and create sufficient proof for submission to the tax authorities.

If you have further questions about our services, feel free to contact us !
We will get back to you as soon as possible.