The firm’s areas of expertise
The firm practises predominantly in tax law. Its work is organised into six practice areas.
International taxation
Residence and domicile
Analysis of tax residence and domicile under French domestic law and the applicable treaties, and securing the date of any change.
Tax treaties
Application of double tax treaties: allocation of taxing rights, withholding taxes, tax credits and elimination of double taxation.
Trusts and foreign structures
Analysis and treatment of the French tax implications of trusts and other foreign structures, including the related reporting duties.
Cross-border transactions
Securing cross-border flows and transactions: distributions, disposals, intra-group financing and investments held abroad.
Wealth structuring
Legal and tax structuring
Organisation of personal and business assets, choice of investment vehicles (financial, real estate) and holding companies where relevant.
Implementing the solutions
Hands-on support in effectively putting in place the solutions selected following the wealth analysis.
Philanthropy and patronage
Support in carrying out philanthropic and patronage projects.
Gifts and succession
Preparing the transmission of your wealth means securing the continuity of your family history while preserving harmony among your loved ones.
Wealth transmission
Anticipating the transmission of wealth and organising succession: gifts, life insurance and the Dutreil pact.
Family governance
Family governance and pacts: setting up family agreements and governance of holding structures.
International successions
Handling cross-border successions and multi-jurisdictional coordination.
Corporate taxation
Management packages
Design of incentive schemes for companies and their directors and founders: management packages, BSPCE, free shares (AGA), preference shares (ADP).
Deals and transactions
Support on pre- and post-deal matters: LBO, OBO, contribution-disposals and gift-disposals, and analysis of reinvestments eligible under article 150-0 B ter of the French Tax Code (CGI).
Corporate secretarial
Corporate secretarial work and preparation of legal documentation: articles of association, shareholders' agreements, SPAs.
Global mobility
Mobility planning
Tax planning for international mobility (inbound and outbound moves), including exit tax and the timing of the move.
Cross-border compensation
Practical recommendations and implementation of cross-border compensation plans: carried interest, options, RSUs and the French inbound (impatriate) regime.
International retirement
Anticipating retirement after an international career and drawing down foreign pension arrangements.
Compliance and disputes
Reporting obligations
Assistance with all your personal reporting obligations: income tax, capital gains, real estate wealth tax (IFI), and reporting of assets held abroad.
Audits and disputes
Tax and social security audits, management of disputes and ruling requests with the French tax authorities.
Modelling and decision-support tools
Some decisions cannot be settled by a legal memo alone. The firm builds bespoke models that put figures on the scenarios under consideration and make their consequences legible, so that choices rest on orders of magnitude rather than on intuition.
Value allocation
Modelling of how sale proceeds are shared between the various financial instruments (the “waterfall”), at every valuation assumption.
Liquidity mechanics
Models combining the financial, legal and tax dimensions to illustrate how liquidity mechanisms work and when they are triggered.
Incentive plans and tax projections
Simulation of incentive schemes and projection of the resulting tax position, for a single director as much as for an entire team.
Tracking shareholdings
Bespoke tools for monitoring financial shareholdings, updated as transactions unfold.
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