International taxation

Assistance with the tax aspects related to the location of a subsidiary or entity abroad and with the structuring of exchanges with foreign entities (equity capital operations, financial flows, operational flows)
Analysis of permanent establishment exposures
Anticipation of tax leakages / withholding taxes on cross-border flows (Articles 115-5, 119-2, 119-3, 119-4, 182 B and 182 B-2 of the French Tax Code), including the analysis of tax treaties
Management of the cash repatriation strategy
Analysis of foreign companies taxation risk (analyses of functions, risks, assets and substance)
Analysis of the taxation risk in France on capital gains accrued by non-resident companies and foreign investment funds (Articles 244-2 A, B and C of the French Tax Code)
Interpretation of international tax treaties and anti-abuse clauses (accessibility of the status of resident and treaty beneficiary, impact of the multilateral instrument)

Relations with Tax Authorities

Assistance in relation with tax audits (phases of control, pre-litigation and litigation)
Assistance for the filing of tax claims
Assistance in preparing and filing certification applications (tax neutral merger regime, deficit transfers, partial asset contributions, etc.) or revisions (e.g. absence of permanent establishment, eligibility of research operations for the CIR tax credit, eligibility for the status of innovative startup)
Assistance in the event of police tax searches

Identification and analysis of opportunities to improve the effective tax rate and the Group’s regular taxation via an in-depth analysis of the operational and financial flows as well as the tax situation of the Group’s main subsidiaries located across several jurisdictions
Analysis of the Group’s intellectual property:

DEMPE (development, enhancement, maintenance, protection and exploitation of intangibles) analysis
development strategy of intangibles and structuring of the R&D activity
research tax credit opportunity and calculation review
opportunity to benefit from the status of innovative startup
opportunity to benefit from France’s patent system (new Article 238 of the French Tax Code) or an equivalent foreign system
review of withholding tax exposures in relation with services and fees (Articles 182 B and 39-12-3 of the Tax Code)

Analysis of risks associated with anti-abuse provisions (articles L64 and L64A of the LPF, articles 209 B, 238 A, 210-0 A, 119-3, Sections 3, 57 of the French Tax Code, etc.) and conventions (abuse of tax treaties, Principal Purpose Test, Limitation On Benefits, effective beneficiary clause, etc.)
Preparation of filings (Articles 209 B, 210-0 A of the Tax Code) and, if applicable, application for rulings

Review of the current tax situation
Detection of tax risks and assistance in implementing corrective actions (regularization, preparation of the documentation)
Introduction of annual subscriptions for commonly asked questions