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Tax Law

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.”

Leaders League – Finance, Restructuring and Tax2021

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.

Newsroom

BERSAY advises Perspecteev on its series A fundraising

Reference
Deals
Le Magazine de l'ANDRH

Télétravail à l’étranger : entre flexibilité et responsabilité

Publication
1 June 2022
Choose Paris Region

BERSAY is member of Choose Paris Region

News
15 February 2022
Tax Law

Les management packages à l’épreuve de l’abus de droit

Article
9 February 2022

BERSAY advises the majority shareholders of Linkbynet, a leading French cloud services provider, on the sale of their company to Accenture

Reference
Deals

BERSAY advises the first impact investment fund dedicated to the cultural and creative industries on the renovation of Hangar Y

Reference
Deals
Option Droit et Affaires

Régime des marchands de biens : l’intention ne vaut pas l’action

Publication
30 August 2021

BERSAY advises Martek on its acquisition of a majority stake in Actinuum

Reference
Deals
Tax Law

BERSAY strengthens its tax department with the appointment of Manuela Bitton as Counsel

News
8 July 2021

Team

Alain
Jouan
Partner
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Manuela
Bitton
Counsel
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Guilhem
Tabard
Associate
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