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Tax law in France

Our tax department offers a complete range of tax services to a diverse clientele, comprised mainly of private or public companies, banks and financial institutions, investment funds or governments.

We are one of the leaders in European mid-market M&A tax transactions and are able to intervene on complex strategic transactions as well as on smaller projects. We also advise on cross-border transactions when one or more parties are not based in the same country as the target company. Our main areas of expertise cover:

  • Mergers and acquisitions
  • Private equity / infrastructure
  • Restructuring / reorganisations / refinancing
  • Carve-out operations
  • Effective tax rate management
  • Joint-ventures

Our tax team works with you to help you avoid tax risks and maximise taxation benefits for your business using our knowledge of the French legal and tax systems and the way they can be reconciled at an international level.

Most of our clients are key players of the following sectors : Energy and natural resources, Food and drink, Industrial engineering, Infrastructure and Private equity.

Our tax services: Transaction tax

  • Due diligence
  • Buy-side / Sell-side tax due diligence
  • International support via the Eversheds Sutherland network and “best friend” firms
  • Remedial actions before exits and after completion of acquisitions

Tax structuring

  • Tax structuring of transactions (tax optimisation, tax consolidation and consolidation of costs and expenses related to the acquisition, securing financial leverage and cash flow, transaction fees, registration fees, VAT / wage tax)
  • Management package expertise
  • Support in the context of pre or post-closing reorganisation operations in order to optimise levers both in France and internationally (carve out, securing rollover schemes, net operating losses, compliance and management re. withholding tax, substance requirements, etc)
  • Preparation and management of relations with tax authorities (cross-border mergers or contribution for shares, transfer of tax losses, etc. )

Modelling

  • Fund flow modelling
  • Determination of tax liability over the Business Plan, in the frame of acquisition or group reorganization, both in France and internationally
  • Tax impact of dividend flows to serve the acquisition debt
  • Debt push down planning
  • Cash trap management / solutions
  • Thin capitalization rules management over a business plan period

Our tax services : General Corporate Tax

Tax strategy

  • Management of the effective tax rate: tax analysis and mapping, review of opportunities, levers and constraints, with the support of the Eversheds Sutherland network and partner firms
  • International tax strategy in the context of international growth transactions (advice on the location of holdings, creation of organic business, subsidiary vs. branch, joint ventures)

Corporate tax management

  • Annual tax reviews
  • Calculation of the income tax liability
  • Expertise with regards to tax consolidation
  • Review of the deduction of financial expenses
  • Taxation of cash flow and compliance, particularly with regards to the
  • application of international treaties
  • Securing the application of international tax treaties (residence, permanent
  • establishment, capital gains)
  • Management of tax losses
  • VAT management for company restructuring and projects

Assistance for tax audits and litigation

  • Tax audit assistance
  • Tax litigation assistance
  • Assistance with tax litigation against the French State (based on French constitutional law or EU law), e.g. in relation to the 3% contribution, horizontal tax consolidation, company value added contribution (CVAE), tax credits, VAT/holding, etc.