Our expertise

Taxation of groups
and Transfer pricing.

Our firm provides long-term advice to French and foreign groups at every stage of their growth, whether it involves reorganisation operations, the structuring of intra-group transactions or the implementation of their transfer pricing policy.

Our expertise

The firm handles the day-to-day tax issues of industrial groups, both nationally and internationally, and is particularly involved in the following areas :

  • Tax consolidation
  • International taxation
  • Transfer pricing
  • Obtaining tax approvals from French Tax Authorities/ rulings
  • Taxation of innovation (research tax credit, JEI, subsidy issues and mastery of EU capping rules, etc.).

Examples
of interventions

Tax consolidation
  • Regular monitoring of tax consolidated groups
  • Obtaining rulings : ruling obtained confirming that despite universal transfers of assets and liabilities having produced its effects at the end of the financial year, without retroactive effect, the transferred company continues to belong to the tax consolidated group until that same date (solution since validated by a finance law)
  • Setting up restructuring operations involving tax consolidated groups
Support for international development support
  • Supporting a transport group in its development in the United Kingdom and the United States
  • Supporting a video game group in its development in Canada
  • Restructuring of a fishing tackle distribution group and reorganisation of the transfer pricing system
  • Assisting architectural firms in their international activities (fixed establishment issues, withholding tax management)
Assistance with transfer pricing obligations
  • Drafting of transfer pricing documentation and management of tax audits for a leading gelatin food and parapharmaceutical manufacturing and distribution group
  • Support in transfer pricing for a fintech in the context of its international development and monitoring of reporting obligations
Tax audit management
  • Transfer pricing: management of tax audits and monitoring of disputes before the administrative courts
  • Holding company domiciliation: management of litigation concerning the questioning of the effective management headquarters of companies domiciled abroad
  • Assistance in the context of tax searches and monitoring of search disputes

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