Assisted the French subsidiary of a Japanese group in the definition of its transfer pricing policy and preparation of the related legal documentation.
- Defended the interests of corporate groups during tax audits, e.g. justification of the transfer pricing policy and acquisition structures
- Assisted natural persons in the regularization of undeclared funds held outside France
- Provided legal advice in connection with and optimized transfers of tax residences outside France
- Assisted companies in their discussions and negotiations with tax authorities in France and abroad (e.g. request for tax approval from the French General Tax Directorate)
- Assisted French subsidiaries of corporate groups in their relationships with their foreign mother company, including in connection with tax charges, distribution of dividends and transfer prices
- Advised French companies and French subsidiaries of foreign groups in relation to the implementation of research tax credits and drafted the related documentation
- Assisted numerous French and foreign global groups in relation to a wide range of tax issues such as analysis, optimization and securitization of the groups’ effective tax rate
- Performed tax due diligences and provided tax structuring advice to French and foreign industrial groups and investment funds in relation to equity investments
- Assisted foreign groups in setting up in France: choice of the most appropriate investment structure, financing, allocation and repatriation of income, enforcement of international tax treaties, etc.