Tax Law

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Agence de communication - Eliott & Markus

Tax Law

Our tax department advises and represents clients on tax matters to help them effectively monitor and optimize their tax liability, as well as reduce the impact of tax reassessments following tax or customs audits.

Our tax department advises French and foreign companies, and corporate groups (SMEs, multinationals and listed companies), as well as corporate executives and individuals in managing the tax aspects of their day-to-day or case by case transactions. The department also assists a number of international companies and investors with their investments in France and French companies with their investments outside France.

Our team works closely with all the firm's other departments to provide comprehensive solutions and then advises clients on implementing them.

Our team has acquired in-depth knowledge of the issues specific to certain business sectors, which enables it to effectively guide clients in their strategic choices. With a large number of international referral firms, Alerion's tax team is well positioned to handle cross-border tax issues.

The team's lawyers regularly provide training in universities, educational institutions and professional associations, and also organize seminars related to current legislative issues. The practice areas covered by the department include a full range of direct and indirect taxation of companies and assets. The team has also developed expertise in real estate taxation and regularly assists real estate professionals with their day-to-day tax issues.

Capabilities

General Taxation

Optimizing the taxation of income flows (dividends, interest, fees, services)
Taxation of research and innovation: optimizing the calculation base of the Research Tax Credit (CIR) and the Innovation Tax Credit (CII) and assisting companies in drafting technical documentation, with the support of specialized engineers.
Assessing tax risks and optimizing corporate tax liability
Monitoring tax losses
Monitoring anti-abuse rules
Monitoring debt at both the domestic and international levels
International tax planning

Corporate Taxation

Acquisition audits and vendor due diligence
Tax structuring of investments and sales of assets
Optimizing the tax consequences of restructurings, acquisitions and transfers of assets
Optimizing the taxation of share transfers

Taxation of Groups

Corporate restructuring
Tax consolidation
Optimizing tax liability at the group level in international contexts
Obtaining tax approvals from French Tax Authorities

Real Estate Taxation

VAT on property and registration fees
Structuring and optimizing the acquisition or sale of real estate assets and/or companies investing predominantly in real estate (SPIs)
Companies with a special tax status, such as real estate and construction companies (SCI, OPCI, SIIC…)
Taxation of rent income and capital gains
Local taxes

Tax Lobbying

Assisting specific trade organizations in defending the collective interests of their members
Class action cases with regard to issues of compatibility with EU law
Advising on parliamentary draft legislation (amendments, questions to the government)
Requesting rulings in both direct and indirect taxation matters

Tax Audits and Disputes

Assisting companies and individuals with tax audits at all stages of the administrative process
Representing clients before administrative commissions
Challenging tax reassessments before French and European Courts

Work Highlights

Advising the restructuring and sale of a group in the private education sector.
Advice to several pharmaceutical groups in managing tax issues specific to their sector.
Assistance of a group of management companies in connection with a public offering of securities, in particular with regard to re-investment (Art. 150-0 B ter of the French Tax Code): drafted tax opinions and obtained approval on the prospectus from the French securities authority (AMF).
Incorporation of structures in several foreign jurisdictions with regard to acquiring and optimizing the resale of real estate assets by foreign investors in France.
Obtention of rulings from the French Tax Legislation Department modifying the VAT rate applicable to several professions.
Defence of numerous companies in a wide range of sectors in connection with transfer pricing monitoring procedures between the companies within a group.
Advising the Algerian government to overhaul the taxation of foreign investments in Algeria.
Assistance to high net-worth individuals with respect to organizing and optimizing the transfer of their French and foreign assets within their family.
Many class action cases, including in relation to VAT, company value added contributions (CVAE), 3% contributions.
Management of several litigation cases challenging real estate valuations conducted by the French tax authorities.
Monitoring regularization procedures on non-declared assets held abroad.
Advice on optimizing the tax treatment of international intra-group financings (France, Belgium, Netherlands and Germany).

General Taxation

Corporate Taxation

Taxation of Groups

Real Estate Taxation

Tax Lobbying

Tax Audits and Disputes

Key Contacts

Christophe Gerschel

Philippe Pescayre

Stanislas Vailhen

Jérémie Mancel-Cottrel

William Mathiotte

Julien Lebel

Ali Bencheqroun

Pierrick Bouchard

Mathilde Colonna d’Istria

Emilie Feix

Prescillia Rongeat

Maxime Sniegula

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