Tax Law

The tax department advises and represents clients on tax matters to help them effectively monitor and optimize their tax liability, as well as reduce the impact of tax reassessments following tax or customs audits.

The tax department advises French and foreign companies, and corporate groups (SMEs, multinationals and listed companies), as well as corporate executives and individuals in managing the tax aspects of their day-to-day or case by case transactions. The department also assists a number of international companies and investors with their investments in France and French companies with their investments abroad. The team works closely with all the firm's other departments to provide comprehensive solutions and then advises clients on implementing them. The team has acquired in-depth knowledge of the issues specific to certain business sectors, which enables it to effectively guide clients in their strategic choices. With an extensive network of international referral firms, Alerion's tax team is well positioned to handle cross-border tax issues. The team's lawyers regularly provide training in universities, educational institutions and professional associations, and also organize seminars related to current legislative issues. The practice areas covered by the department include a full range of direct and indirect taxation of companies and assets. The team has also developed expertise in real estate taxation and regularly assists real estate professionals with their day-to-day tax issues.

General Taxation
  • Optimizing the taxation of income flows (dividends, interest, fees, services)
  • Taxation of research and innovation: optimizing the calculation base for calculating the Research Tax Credit (CIR) and the Innovation Tax Credit (CII) and assisting companies in drafting technical documentation, with the support of specialized engineers.
  • Assessing tax risks and optimizing corporate tax liability
  • Monitoring deficits
  • Monitoring anti-abuse rules
  • Monitoring debt at both the domestic and international levels
  • International tax planning
Corporate Taxation
  • Acquisition audits and vendor due diligence
  • Tax structuring of investments and closing
  • Optimizing the tax consequences of restructurings, acquisitions and transfers
  • Optimizing the taxation of share or asset transfers
Taxation of Groups
  • Corporate restructuring
  • Tax consolidation
  • Optimizing tax liability at the group level in an international context
  • Tax approvals
Real Estate Taxation
  • VAT on property and registration fees
  • Structuring and optimizing the acquisition or sale of real estate assets and/or companies investing predominantly in property (SPIs)
  • Companies with a special tax status, such as real estate and construction companies (SCI, OPCI, SIIC…)
  • Taxation of rent income and capital gains
  • Local taxes
Fiscal Lobbying
  • Assisting specific trade organizations in defending the collective interests of their members
  • Class action cases with regard to issues of compatibility with EU law
  • Advising on parliamentary draft legislation (amendments, questions to the government)
  • Requesting rulings in both direct and indirect taxation matters
Tax Audits and Disputes
  • Assisting companies and individuals with tax audits at all stages of the process
  • Representing clients before administrative commissions
  • Challenging tax reassessments before French and European courts
  • Advised on the restructuring and sale of a group in the private education sector.
  • Advised several pharmaceutical groups in managing tax issues specific to their sector.
  • Assisted a group of management companies in connection with a public offering of securities, in particular with regard to re-investment (Art. 150-0 B ter of the French Tax Code): drafted tax opinions and obtained approval on the prospectus from the French securities authority (AMF).
  • Conceived and put in place structures in several foreign jurisdictions with regard to acquiring and optimizing the resale of real estate assets by foreign investors in France.
  • Obtained rulings from the French Tax Legislation Department modifying the VAT rate applicable to several professions.
  • Defended various companies in a wide range of sectors in connection with transfer pricing monitoring procedures between the various companies within a group.
  • Mandated by the Algerian government to overhaul the taxation of foreign investments in Algeria.
  • Provided assistance to high net-worth individuals with respect to organizing and optimizing the transfer of their French and foreign assets within their family.
  • Involved in class action cases, particularly in relation to VAT, company value added contributions (CVAE), 3% contributions.
  • Managed several litigation cases challenging real estate valuations conducted by the tax authorities.
  • Tax adjustment procedures on assets held abroad.
  • Advised on optimizing the tax treatment of international intra-group financings (France, Belgium, Netherlands and Germany).