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Tax law

With more than ten lawyers, the Tax Department helps its clients optimise and manage the burden of tax law in the context of their businesses or investments. It also undertakes their defence before the tax administration or the customs authorities at both the inspection stage and before national or European courts.

The Tax Department advises French and foreign companies or groups (small and medium-sized companies, multinationals and listed companies), company directors and natural persons on the tax management of their everyday or exceptional operations. It also assists many foreign entities and investors with their investments in France and French operators with their investments abroad. It works closely with all the firm’s other departments to propose complete solutions and support clients in their implementation. It has thus acquired a profound understanding of the problems specific to certain sectors of activity which enables it to guide clients in their strategic choices. Thanks to an extensive network of foreign correspondents, Alérion’s French team can handle problems of cross-border taxation. Its members regularly give training courses at universities, colleges and professional consortiums and periodically organise presentations on recent changes in legislation. The department’s activities cover all aspects of the direct and indirect taxation of companies and their assets. In that respect, it regularly assists property professionals with their daily taxation problems.

Skills

The general taxation system

- Optimising the fiscal aspects of income flows (dividends, interest, fees, services)
- Tax on research and innovation : optimising the calculation base for the research tax credit [CIR] and helping companies draft their technical documentation, in partnership with specialist engineers
- Optimising the tax burden borne by companies and assessing the tax risks
- Managing deficits
- Managing anti-abuse rules
- Managing debts at national and international level
- Applying international agreements

Tax on transactions

- The acquisition audit or vendor’s due diligence
- The fiscal structure of investments or disinvestments
- Optimising the tax consequences of restructuring, acquisition or transfer operations
- Optimising the taxation on transfers of securities or assets.

Tax on groups

- Company restructuring
- Fiscal integration
- Optimisation of the group’s tax burden in an international context
- Fiscal approvals

Property tax

- VAT on property and registration fees
- Companies with an exceptional tax status (non-trading real-estate and construction company [SCI], OPCI, SIIC, etc.)
- Taxation of rents and capital gains
- Local taxes

Wealth tax

- Family transmission (gift/inheritance)
- Audit of assets and liabilities
- Assistance with leaving or returning to France
- The taxation of income and wealth (income tax, ISF)
- The organisation, management and transmission of professional assets
- Management package

Fiscal lobbying

- Assisting professional associations to defend the shared interests of their members
- Class actions on problems of compatibility with Community law
- Assisting with parliamentary operations (amendments, questions to the government)
- Requesting official replies on direct and indirect taxation systems

Monitoring and disputes

- Assistance with tax inspections (companies or natural persons) at all stages of the proceedings
- Assistance before administrative commissions
- Disputing tax demands before the French or European courts

Important missions

- Assisting several property companies to optimise cumbersome restructuring operations.
- Optimising the tax aspects of the use of patents in an international group.
- Monitoring the restructuring and sale of a private education group.
- Helping several pharmaceutical groups to manage their sectoral tax problems.
- Restructuring industrial groups before the disposal of some of their assets.
- Helping management companies with a public offer of financial securities setting up an ISF (TEPA) or IR (Madelin) right : drafting the fiscal opinion and discussing the prospectus with the Financial Markets Authority [AMF].
- Monitoring the tax inspections of a publishing company which resulted in the abandonment of tax demands concerning 182B retentions at source deducted from the sums paid in exchange for the acquisition of reproduction rights.
- Designing and setting up structures in several States for achieving and optimising the resale of property assets in France by foreign investors.
- Obtaining official replies from the Tax Legislation Department and modifying the VAT rates applicable to several professions.
- Defending companies in all sectors in the context of procedures for monitoring the prices of transfers made between the various companies in the group.
- A mission on behalf of the Algerian Government concerning the revision of the taxation system applied to foreign investments in Algeria.
- Assisting owners of private wealth to organise and optimise the transmission of their French and foreign assets in a family context.
- A class action concerning VAT which resulted in the reimbursement of the VAT on margin paid by shopkeepers on the grounds of its illegality under Community law.
- Conducting acquisition audits on behalf of industrial operators or investment funds.
- Handling several cases disputing property valuations made by the tax administration.
- Tax adjustment procedures on assets abroad.
- Helping optimise the taxation system governing intra-group financing arrangements in an international context (France, Belgium, the Netherlands and Germany).

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