All tax matters related to usual company transactions, including :
Review and determination of taxable income (including management of tax losses carry forward and of the tax burden, interest deduction, asset vs. expense, depreciation and provision);
Management of tax consolidation (including tax consolidation agreements, horizontal tax consolidation, tax burden between consolidated companies, neutralization of interco transactions);
Management of dividend distributions, interest, royalties and intra-group services;
Application of international tax treaties (with the assistance of our partner law firms, if necessary);
Coordination with our correspondents on foreign tax aspects.
Taxation of exceptional transactions, including :
Capital increases and reductions, asset contributions, mergers;
Request for approval from tax authorities (loss transfers, mergers, asset contributions);
Tax assistance related to the acquisition or sale of companies/businesses in France and abroad (generally with our correspondents);
Tax provisions related to share purchase agreements, business sale agreements and shareholders’ agreements;
Structuring acquisition and sale transactions.
Taxation of top-management/executives, management packages (free shares, stock options, preference shares)
Tax strategy: assistance in the choice of localization and establishment of our clients worldwide