Companies with an international focus
From start‑ups and SMEs to mid‑caps and multinational groups, whether French or foreign, first‑time exporters or experienced ones, we stand by your side at every stage of your international journey.
Sector:
Carpentry
French SME
Analysis of the tax impacts on a group of companies associated with the departure abroad of the founding managing partner
Net sales:
€2 M to €10 M
Areas covered:
France
Assignment
- Permanent establishment analysis
- Presentation of the deductibility conditions for management fees invoiced by the CEO following his departure abroad
- Assessment of issues related to the business termination of a holding company and transfer of going concern
- Advisory on structuring post-departure operations and drafting a memorandum on responsibilities towards the newly appointed management
- Drafting of intercompany agreements
Approach:
Human and legal support to ensure the group’s continuity and compliance.
Sector:
Agro Chemical Industry
French medium-sized enterprise owned by family and private equity funds
Continued assistance in the management of transfer pricing issues for the French company and its foreign subsidiaries
Net sales:
€750 M to €1 B
Areas covered:
Europe de l'Ouest, Asie, Amériques (Sud et Nord)
Assignment:
- Review of the transfer pricing policy applied in all business units of the group
- Management of issues related to permanent establishment
- Support for restructuring operations in coordination with local advisors
- Drafting of documentation templates and performance of economic analyses
Approach:
A close collaboration with the finance department to secure the group’s international taxation in the long term
Sector:
Chemical industry
French medium-sized enterprise owned by family and private equity funds
Ongoing international tax and transfer pricing assistance
Net sales:
€400 M to €750 M
Areas covered:
Western Europe, Morocco, Brazil, China, India, United States
Assignment:
- Analysis of the tax impacts of a cross-border business transfer
- Advisory on the restructuring of a foreign subsidiary and assessment of impacts on French companies (analysis and modeling of key issues)
- Review or drafting of contracts and documentation, including declaration form 2257
- Support during tax audits in France and abroad
Approach:
A technical and operational partnership to secure the group's international operations
Sector:
Online training
French Small scale enterprise
Analysis of the tax consequences associated with the departure abroad of the sole managing founder and partner, working alone in his company.
Net sales:
€500 K to €2 million
Areas covered:
France
Assignment:
- Permanent establishment, business transfer and business termination analyses
- Structuring of invoicing flows following the departure of the CEO abroad
- Evaluation of the impacts on deferred taxation arising from the prior contribution of the founder’s sole proprietorship to a company
Approach:
Customized support to confidently navigate business transitions within challenging tax environments
Sector:
Software - Finance
French Start-Up - Serie B
Definition and set-up of a transfer pricing policy adapted to rapid international growth
Net sales:
€10 M to €50 M
Areas covered:
France, United Kingdom, United States
Assignment:
- Review of the historical transfer pricing policy
- Set-up of a new transfer pricing framework
- Drafting of intercompany agreements
Approach:
A pragmatic and adaptable approach to support the group’s international expansion
Sector:
Mutuals and Insurances
French multinational
Revision of transfer pricing documentation to comply with the obligations applicable in the group's countries
Net sales:
€750 M to €1 B
Areas covered:
France, Belgium, Italy, Italy, Spain, Spain, Portugal, Morocco
Assignment:
Review existing documentation and prepare materials for uncovered entities, including economic analysis
Approach:
Joint work with the tax department to support internal skill development on a matter of rising significance for the group
Sector:
Agro Chemical Industry
French family owned multinational
Support for the tax department in close coordination with the group's financial and legal departments.
Net sales:
€3 B to €5 B
Areas covered:
Europe, Africa, China, North America, South America
Assignment:
- Review of the various transfer pricing policies applied in each division, documentation and drafting of contracts
- Review of the remuneration model for R&D activities and technological licenses (IP box)
- Support in the definition of the remuneration strategy for brands centralized at the holding level (DEMPE analysis and recommendations)
- Review of transfer pricing issues in connection with group restructuring
- Support in the management of tax audits (review of responses, preparation of reports), definition of strategy
Approach:
A long-term partnership based on trust, technical rigor and the co-construction of solutions adapted to the group's challenges.
Sector:
Business services
French family owned multinational
Support to the financial and accounting department following a tax reassessment challenging differences in royalty rates between geographical areas
Net sales:
€3 B to €5 B
Areas covered:
Europe
Assignment:
- Definition of a tax audit strategy considering impacts at group level
- Drafting of the reply to the proposed tax adjustment and participation in hierarchical appeal
- Identification and defense of a corroborative method following discussions with the tax authorities
- Management of relationship with the tax authorities within the framework of a global settlement procedure
- Coordination of mutual agreement procedures to eliminate double taxation
Approach:
A targeted and collaborative intervention to secure the group’s position in the context of a tax audit involving a cascading invoicing chain, resulting in double taxation within the tax consolidation as well as additional international double taxation.
Sector:
Sportwear
French subsidiary of an Italian listed group
Long-term assistance to the French company and its subsidiaries, along with support following integration into an Italian group.
Net sales:
€750 M to €1 B
Areas covered:
France, Spain, UK, Italy
Assignment:
- Redefinition of the transfer pricing policy following the evolution of the operational model
- Assistance during tax audits (preparation of responses to administrative requests, drafting of transfer pricing documentation, participation in meetings with the tax authorities, reply to proposed adjustments, full relief obtained)
- Coordination with the Italian group on tax issues related to the transfer pricing policy applied by the company prior to its acquisition
- Drafting of transfer pricing documentation and review of form 2257
Approach:
Collaborating closely with both local and Group finance teams to align and coordinate interests at every level