Tax review of valuations

  • Review of the value analysis in relation with sales and acquisitions in order to ensure that the latter is consistent with tax authorities’ methodologies
  • Review of fair market valuation to determine if the contribution value, the purchase price used for an intragroup sale or the merger exchange ratio is consistent with tax authorities’ methodologies
  • Review of brand and other intangible assets valuations to ensure that they are consistent with tax authorities’ methodologies
  • Review of the valuation documentation with tax authorities or statutory auditors

These missions may be undertaken in coordination with your financial advisors engaged in the valuation and its documentation.

Purchase price allocation

  • Review of the value assigned to intangible assets distinct from goodwill (brands, patents, client relations, etc.) and allocation of the goodwill taking into account tax rules (Base Erosion and Profit Shifting) and in light of the company’s tax strategy
  • Assistance with the declaration of values for tax reporting purposes, notably American (should 338 (g) or other statutes be applied)
  • Coordination with legal and financial advisors as regards the values to be selected for intragroup reclassifications (of assets or securities) or post-acquisition reclassifications (possibility of asset / goodwill depreciation, capital gains taxation should securities or assets be reclassified, recording rights, employee participation)

These missions may be undertaken in coordination with your financial advisors engaged in the valuation and its documentation.

Transfer pricing documentation

  • Critical review of the transfer pricing documentation
  • Risk analysis in the event of unjustified or inadequately documented flows (transfer of proceeds abroad, etc.)
  • Assistance in negotiating unilateral, bilateral or multilateral agreements with the tax authorities
  • Assistance in carrying out trading or amicable resolution procedures

These missions may be undertaken in coordination with your financial advisors engaged in the valuation and its documentation.