Lawyers in the firm’s Tax Law department advise corporates, be they large, intermediate or small, as well as private individuals on their tax strategy and management, in France and abroad, and represent them in their dealings with the tax authorities.
The objective is to provide clear answers and concrete solutions in the field of taxation by combining technical expertise, creativity and pragmatism.
Bersay’s tax lawyers are also involved, alongside the Corporate team, in the tax structuring of all transactions, particularly in the context of mergers and acquisitions, corporate reorganizations and private equity operations.
“ BERSAY is admired for its responsiveness, the robust nature of its services and its sharp corporate-tax expertise.”
Their in-depth knowledge of the tax authority landscape enables them to negotiate special solutions by requesting clearances and advance tax rulings to secure the transactions entrusted to them.
Bersay’s tax lawyers also assist clients with tax audits and litigation before the judicial and/or administrative courts.
As taxation evolves in line with public policies, particular attention is paid to monitoring legislative, regulatory and case law developments, through regular technical monitoring, the provision of training on specific subjects and participation in numerous seminars and conferences (EFE, IACF, IFA, AFIC, France-Invest, etc.).
Areas of expertise
Assistance with routine domestic tax matters (tax consolidation, corporate tax, parent-subsidiary regime, thin capitalization, local taxation, VAT, etc.) and with the international taxation of companies or groups; advice on foreign investments in France and French investments abroad (permanent establishment, taxation of cash flows, etc.); tax structuring of internal reorganizations of groups (mergers, partial asset contributions, spin-offs, request for transfer or maintenance of losses, etc.).
Tax structuring of transactions and assistance in the negotiation and drafting of contractual agreements; implementation of profit-sharing and incentive mechanisms for executives and employees.
Assistance to French and international private clients with their tax returns and real estate wealth tax; assistance with the transfer of assets, both movable and real estate (gift, estate, lock-up arrangements and partial exemptions under Dutreil pacts); regularization of assets held abroad; assistance in matters of foreign trusts, foundations and endowment funds.
Handling of all dealings with the tax authorities, whether in the adversarial phase of the tax audit (responses to notices of proposed tax deficiency, appeals to a higher administrative body) or in the litigation phase (claims and proceedings before the administrative, civil or criminal courts); assistance to clients during searches and with criminal proceedings, including tax fraud cases.
Structuring and securing transfer pricing policies and structuring of intra-group flows, for both routine and exceptional operations; preparation of required documentation supporting pricing policies under French and international rules (drafting or updating of Master File and Local File) and of specific returns (simplified form 2257 or CbCR 2258); management of relations with the tax administration in the context of tax audits, out-of-court procedures or prior agreements on transfer pricing.
Direct or indirect tax issues related to the acquisition, construction, operation and/or sale of real estate (registration fees, corporate income tax, VAT on real estate transactions, 3% tax and specific property taxes).
Tax assistance to associations, foundations and endowment funds, as well as companies operating in the social and solidarity economy.
Assistance to corporates and groups with new international tax obligations such as BEPS, DAC 6, and country-by-country reporting requirements.