Real situations, bespoke strategies
Matters handled by the firm, and the tax and wealth strategies the firm puts in place to address them.
34 case studies
Wealth structuring
05Acquiring a Family Property in France
Structuring the acquisition of a French residential property for an international family: choice of vehicle (SCI, SARL, SAS), financing, use and French real estate wealth tax.
Structuring the acquisition and growth of a pharmacy through an SPFPL
Acquiring a stake in a pharmacy through an SEL and an SPFPL: choice of structures, financing, cash flows, the parent-subsidiary regime and governance of regulated professions.
Structuring a director’s shareholdings and investments through a holding
A director holding their operating company and several shareholdings: pooling through a holding, parent-subsidiary regime, organisation of flows and preparation of the transmission.
Pooling and passing on financial assets within a family holding
A family holding a diversified financial portfolio: family SAS, pooling of investments and private equity, bare-ownership gift and transmission without joint ownership.
Choosing the right structure to grow your professional practice
A regulated professional looking to acquire more shares and grow: comparing direct ownership, an ordinary holding company or an SPFPL, financing, the parent-subsidiary regime and the social-contribution risk on dividends.
Companies and compensation
12Opening up your company’s capital while preparing succession
Advising a founder-director on a private equity fund entering the group’s capital: liquidity, reinvestment and family succession within a single coherent strategy.
Securing your management package ahead of a sale
Executive holding several incentive instruments: characterisation of the gain, modelling of the net after-tax amount, valuation and preparation for the liquidity event.
Rewarding your first employees with BSPCE
Involving a young company’s first employees through BSPCE: eligibility, plan design, exercise of the warrants, valuation, payroll reporting and capital increase.
Creating a bespoke management package for the founders of a new company
Designing a bespoke management package for the founders of a new company: comparing instruments, preference shares, taxation (article 163 bis H) and the articles of association.
Selling your company and reinvesting through a contribution-disposal
A founder selling their company to an industrial group: balancing personal cash and reinvestment, contribution-disposal (150-0 B ter) and an eligible reinvestment strategy.
Selling or reinvesting shares received as an employee
An employee holding RSUs and shares ahead of a liquidity event: distinction between acquisition gain and capital gain, article 163 bis H, net simulation and contribution to a holding.
Securing the management fees paid to directors’ holding companies
A group whose directors act through their personal holdings: mapping of duties, management fees agreements, deductibility, VAT and risk of social security reclassification.
Identifying IP Box eligible assets within an SME group
An SME group exploiting a brand and in-house software: mapping of intangible assets, IP Box eligibility of the software, splitting of income and 10% rate election.
Structuring and securing carried interest for a management company’s partners
The partners of a management company launching a new fund: structuring the vehicle, tax regime (article 150-0 A, II, 8° of the CGI), vesting, departures and monitoring of distributions.
Qualifying a Group RSU Plan for France
A global RSU plan applied to France with no addendum: every delivery taxed and charged as salary. Five ancillary clauses stood in the way of qualification; a French addendum removed them, without touching the global plan.
Choosing the Instrument Before a Sale: Salary, Free Shares or Co-investment
One million euros to be paid to each of five executives at the time of the sale. The amount was settled, the instrument was not: three routes modelled, and a gap of €204,600 per person for the same value delivered.
Comparing a Cash Bonus with BSPCE Before Settling the Plan
On a €900,000 gain, the gap between a bonus and BSPCE reaches €184,140 for the beneficiary, and the company bears no charge at all. Provided it meets the eligibility conditions, which exclude most fund-backed structures.
Global mobility
08Returning to live and work in France after several years abroad
Advising a senior executive returning to France: date of tax residence, inbound (impatriate) regime, treatment of foreign income and assets, and IFI for new residents.
Being the beneficiary of a foreign trust while resident in France
French-resident beneficiary of a foreign family trust: characterisation of the trust, reporting obligations and tax treatment of distributions.
Planning Retirement After an International Career
Cross-border retirement planning: consolidating pension rights across countries, comparing dates and payment options, tax treatment of foreign pensions and a withdrawal strategy.
Leaving France while keeping a significant shareholding in a company
An entrepreneur leaving France while retaining shareholdings: tax residence, exit tax (article 167 bis of the CGI), share valuation, payment deferral and post-departure follow-up.
Securing your tax residence when moving abroad
A director moving abroad while keeping ties with France: residence criteria (article 4 B of the CGI), tax treaty, evidence file and consequences of the departure.
Advising a US citizen settling in France
A US person settling in France on a long-term basis: France–US tax coordination (FBAR, FATCA, PFIC, CFC), review of investments, trusts, real estate and succession.
Hiring a first employee in France
A foreign company hiring its first employee in France without a subsidiary: choice of employment structure, employer registration with the Urssaf, French payroll and permanent-establishment risk.
Securing the taxation of carried interest during an international relocation
A private equity professional moving to France with carried-interest and co-investment rights in foreign funds: eligibility for the regime (articles 150-0 A and 163 quinquies C of the CGI) and coordination with mobility.
Gifts and succession
04Passing French real estate on to your children when the family lives abroad
Gift of French property by a family resident abroad: shared gift (donation-partage), reserved usufruct, protection of the surviving spouse and French–Italian coordination.
Organising the transmission of your wealth while protecting your loved ones
A transmission strategy across spouse, children and grandchildren: gifts, bare-ownership, spousal protection and coordinated life-insurance beneficiary clauses.
Organising an international succession
A family whose wealth is spread across France and abroad: applicable law, inheritance tax in each country, double taxation and a roadmap for the heirs.
Passing on a family group using the Dutreil pact
Founders of a family group planning its transmission: comparing a Dutreil pact on the operating company, an animating holding and a pact through interposition.
Compliance and disputes
05Regularising previously undeclared foreign accounts
Voluntary disclosure of omitted foreign securities accounts: reconstructing the flows, years to correct, exposure to penalties and lasting compliance.
Declaring dividends paid from abroad
Foreign-source dividends received by a French resident: form 2778-DIV-SD, withholdings, treaty tax credit and consistency with the annual return.
Supporting a financial institution with its tax and reporting obligations
A financial institution serving French tax resident clients: tax treatment of products, return no. 2777, production of the IFU statements and tax management of PEAs.
Challenging a reassessment in respect of the IFI
An audit of the value of real estate held directly and through an SCI: reconstructing the values, illiquidity discount, response to the reassessment and time limits.
Regularising Crypto-Asset Wallets Held Abroad
Voluntary regularisation of undeclared crypto-asset wallets and of the corresponding capital gains: characterising the accounts, reconstructing the portfolio, exposure to penalties and the request for remission.
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The essentials, country by country
Clear pointers on frequent situations of mobility and international taxation.
Personal taxation in Monaco
Income tax, IFI, exit tax and succession according to nationality.
Read the guide→MaltaMoving to Malta
Tax residence, remittance basis and special regime for a French national.
Read the guide→ItalyMoving to Italy
Flat tax regime for new residents, capital gains, exit tax and succession.
Read the guide→United Arab EmiratesMoving to the United Arab Emirates
Tax residence, Corporate Tax, exit tax and income still taxable in France.
Read the guide→A glossary of the key mechanisms, explained simply
Dutreil pact, holding companies, contribution-disposal, bare-ownership gifts… the main concepts that recur in the firm’s case studies, defined without jargon.
Disclaimer.Each case shown was handled by the firm, in light of the law and case law in force at the time of the engagement and in the light of circumstances specific to it. These examples are provided for illustration only: they do not constitute advice and do not predetermine the treatment that might be adopted in another matter.