Taxation

Preferential tax treatment for limiting the financial cost of acquisition debt bt granting of tax reductions for the indebted holding for the takeover.

Preferential tax regimes for reorganising companies with limited tax costs with, in return, phased reintegration and/or deferred unrealised capital gains while restructuring (capital gains tax deferral and tax reversals).

Establishment of foreign holding companies with minimal substance to prepare a cash transfer following profits in optimised tax conditions; dividend exemption, exemption from capital gains, deductibility of loan interest, no deduction of taxes at from holding company to the financial beneficiary

Combined implementation of tax and social security rules in order to reduce the overall tax ratio applicable to income from activities and property income for people who carry out most of or all of their business activates abroad.

Pre-litigation and litigation on the legality of parafiscal taxes in regards to the principles of French community law in order to challenge their legality, especially in the absence of notification to the commission in the event of a substantial modification of their regime and their quality of

Employee share ownership and sui generis which develop indirect/additional compensation benefiting from a preferential tax and/or employment treatment in relation to a direct compensation as salary.

Choosing the most appropriate tax vehicle: French listed property investment companies (SIIC), collective undertaking for real estate investment (OPCI), foreign structure, arbitration between transparent and opaque tax regimes etc.

Property audit leading to the recommendation of the most appropriate tax revenues given the structure of revenues to mitigate income tax: LMP (non-professional furnished letting), Loi Girardin, French overseas departments and territories (DOM TOM), Share Savings Plan (PEA), high-risk mutual fund