Specialist tax lawyers

Private wealth tax matters, taxation of company directors and advice to entrepreneurs

We advise our clients on a daily basis on their private wealth tax matters (income tax, real estate wealth tax, capital gains, trusts). Our team also advises on the transfer of family businesses, the transfer of private wealth, and domestic and international wealth and succession planning (Dutreil pacts, splitting of ownership between usufruct and bare ownership).

We also assist with setting up wealth-holding companies and with the taxation of remuneration and incentive schemes, in particular management packages.

Please note: The firm supports long-standing clients at each stage of their development: setting up holding companies, tax returns, incentive schemes, contribution-and-sale transactions, gifts and successions.

Tax aspects of transactions, financing and restructurings, and tax audits

We advise our clients on all tax matters arising from mergers and acquisitions, including tax due diligence, tax structuring and the tax review of transaction documents.

Our expertise covers the determination of taxable profits, tax consolidation, registration duties, CVAE and property taxes, as well as the review of tax attributes such as carried-forward losses, tax credits, provisions, depreciation, special regimes, tax rulings, and ongoing audits and disputes.

We also advise on the limitation of financial expenses (ATAD 1), tax consolidation (implementation, monitoring and optimisation), tax clearances, the management of intangibles, the tax review of financial models, and financial taxation. Finally, we advise holding companies on specific issues such as VAT and payroll tax.

Please note: The firm has recognised experience in international structuring, in particular in the United States and Greece.

Preparing tax returns for individuals and businesses, and assisting with voluntary disclosures

We assist our clients in preparing and filing their tax returns with the French tax authorities, including income tax, real estate wealth tax, the 3% tax on French real estate, and trust reporting, whether annual or event-driven.

We also advise on the non-final withholding tax on investment income (PFNL) and on specific filings such as the reporting of cross-border arrangements (DAC 6).

Please note: The firm has solid experience in the reporting of foreign-source income.

Voluntary disclosures to the French tax authorities

We specialise in filing voluntary disclosure returns, whether for income tax, real estate wealth tax, gift and inheritance tax, or the reporting of assets held abroad.

Please note: The firm has assisted a considerable number of clients in their dealings with the French tax authorities.

Support during tax audits of businesses and individuals, responses to requests from the tax authorities, administrative appeals and litigation before the competent courts.

We assist individuals and businesses during tax audits, providing full support at every stage. We respond to requests from the tax authorities, whether for information, explanations or supporting evidence.

We also act in accounting audits, personal tax position reviews (ESFP), administrative appeals to senior officials and meetings with the departmental interlocutor.

We assist our clients with applications for discretionary relief and in litigation before the competent courts, whether civil or administrative, as well as on tax criminal law matters.

The firm is able to map the principal tax risks in advance and to assist taxpayers in the tax audit that follows.

Assistance during tax searches and seizures

The procedure under Article L. 16 B of the French Tax Procedure Code allows the tax authorities, with the authorisation of the liberty and custody judge, to carry out searches and seizures in any premises, including private ones, in order to gather evidence of conduct capable of amounting to tax fraud (seizure of documents, telephones, computers, diaries and so on).

We assist individuals and businesses facing a tax dawn raid, from the conduct of the operations themselves through to the appeals that may be brought.

The firm is able to map the principal tax risks in advance and to assist taxpayers in the tax audit that follows.

Please note: Given the appeal deadlines and what is at stake in a search and seizure procedure, involving a tax lawyer in the first hours makes it possible to identify any irregularities quickly and to prepare the taxpayer's defence strategy.

Real estate investment: acquisition, structuring, financing and operation

We assist our clients with the reporting and optimisation of real estate wealth tax (IFI) and with the management of their rental properties, whether let unfurnished, or furnished on a professional or non-professional basis.

We advise on the structuring of real estate investments and on the choice of vehicle — SCI, OPCI/SPPICAV, OPPCI, SCPI or the SIIC regime — and on compliance with the conditions attaching to each of those regimes, as well as on tax reviews of assets and vehicles, ahead of an acquisition, a disposal or a restructuring.

Our expertise also covers the 3% tax, VAT on real estate, registration duties, and the taxation of rental income and real estate capital gains.

Please note: The firm advises a wide range of French and international clients on specific regimes: social housing, listed historic buildings, property dealers, and the LMNP/LMP furnished rental statuses.

Taxable status, exemptions and rates

We advise our clients on taxable status and rates, on reporting and formal obligations, and on invoicing rules, in order to secure full and reliable VAT compliance.

Please note: The firm has handled a significant number of tax audits relating to VAT and has broad experience in the field, including financial services VAT and VAT for copyright collecting societies.

Taxation of artists' income

We assist French and foreign creative artists and performers with their tax filings and tax disputes.

Please note: The firm advises copyright collecting societies, among others.

Art market taxation

We advise collectors, artists, galleries, artists' estates, foundations and other art market participants on the management and optimisation of their tax position, in France and internationally.

Our expertise covers every tax issue arising from the acquisition, holding, transfer and sale of works of art. It also covers the specific questions raised by successions.

Please note: The firm regularly advises a range of creative artists, including visual artists and performers, as well as artists' heirs.

Advice on the tax obligations specific to non-profit organisations and to philanthropy

We advise non-profit organisations on the special tax regimes applying to endowment funds, foundations and associations, as well as on the prevention and management of tax risk and on the reporting obligations specific to these structures.

Please note: The firm is regularly instructed by cultural institutions to secure their activities and to assist with their philanthropy and sponsorship programmes.