Boosted tax team
Building an enhanced tax relation
Our approach :
create a fiscal partnership
Our approach is based on an expertise built in Big 4 as partner in France and abroad but also as tax director of complex and well-regarded in-house organization for a US financial and industrial multinational. This hybrid experience allows us to be flexible and able to work hand to hand with our clients as a unique team, familiar with operational constraints and considerations.
An organization may require sophisticated tax support only as a complement of existing available resources for a given operation or a definite period of time: this is why we offer to help companies maximize their internal resources, to build their priorities as well as on the culture of the organization.
Our objective is to build an enhanced tax partnership where our services are tailored to a specific need and the market constraints and offer an independant advice and point of view.
We may also help building and validating tax priorities, all while sharing knowledge and benchmarks on the most efficient tax organization. Our connections and established reputation as an ethical firm on the French market may even be useful to identify and assess candidates that may join your organizations.
The above mindset allows us to simply and very efficiently adjust actual tax support needed according to concrete technical needs, level of priorities and budget constraints. The idea, if efficient, is to leverage on internal resources allowing to tailor made the scope of our intervention.
Our organization as an « agile niche boutique » allows to avoid conflict between our clients and guaranties top of the market ethics and confidentiality as requested by the current market.
If need be, we are working with highly regarded professionals outside of our firm, in France or abroad.
Boosted tax team :
We aim to offer an on-demand tax service to supplement existing resources in an efficient way. It may be only few hours/days per month and can be for instance split into two phases: diagnostic/priority meeting, followed by support for implementation of identified opportunities over time. The methodology is to keep the “in house” approach, i.e. deliver answers taking in account operational constraints, then used to clarify and understand the actual level/nature of the question. We generally work on a fixed budget and are extremely careful in keeping track of the know-how exchanged during our interventions.
We propose to implement a process for risk mitigation/optimization, especially during regular or yearly closings. We may participate to statutory audits process to maximize financial benefit deriving from tax but also maintain the risks under full control. One of the objectives is to share market benchmarks with an independent view and help groups to manage efficiently their tax line (eg Fin 48 under USgaap or Ifric 23 under IFRS).
Enhanced relation programm (“Relation de confiance”) :
Since the so called ESSOC law in 2019, France has created an enhanced relation program (« relation de confiance »). This may prove an asset for big and medium size groups, including foreign groups, who seek to improve their transparency so as to obtain a more fluid and efficient relation with the French tax authorities.
As a recognized top market player on this subject, we can assist companies in building a cost/benefit analysis as part of the enhanced relationship: diagnostic, strategy, priorities to be included in the process…etc. This may result in significant opportunities in an unstable Post-Covid period, as along with optimization of both funds and resources. Our method also consists in, when possible, training the internal resource for them to come to handle the process autonomously over time. During our activity, we have been helping several companies to better their enhanced relation program participation and have been consulted on several occasions by the authorities to suggest corrections or improvements.
Transfer pricing and cross border tax
As we all know, international tax may prove complex, therefore requiring additional support or views for existing teams. This is particularly true for transfer pricing and analysis of the tax consequences of cross border transactions. Moreover, this is also verified when overall tax strategy is designed worldwide, yet may necessitate some marginal adjustments to meet the French market’s approach. Our goal is to provide a very flexible support that may be organized following the direction of our recognized experts in international tax. We focus on our ability to (recaticvité) and propose practical and straightforward solutions that can be implemented.
Tax strategy to support social negociations
We have noticed, on the French market, an increase of tax discussion during social conflicts especially for non-French groups. This is sometimes because a portion of the remuneration of the employees is based on the taxable profits increasing sensitivity. We also noticed that the tax treatment of social plans is sometimes not fully in line with what it should be when social plans include synergies deriving from relocation outside France. As tax may be critical, we are sometimes involved early in the discussion allowing all parties to discuss based on actual knowledge of tax consequences of decisions. We may also help accessing State representatives to find solutions acceptable by all parties. Tax is very often an efficient tool not always used.
Assistance for internal and exernal acquisitions and reorganisations :
Internal or third-party reorganization and restructuring are key for businesses in particular in the current environment. The objective is to adjust our approach based on actual situation from a one-time proposal to a more integrated offer embedded in an existing tax team.
We keep an “in house flavor” compatible with operational and non tax constraints and a creative approach.
Settlement of complex tax conflicts:/litigation
In addition to our assistance in managing your tax audit strategy as well as tax litigation, the French tax system offers alternative means of settling complex tax discussions and possible tax criminal consequences (sometimes automatic at the end of a tax audit). We can share our experience on this using our knowledge deriving from an inhouse experience for a US multinational. The objective is to maximize all potential opportunities before entering a litigation process. We deliver a global view that includes side consequences eg tax reputation, employee profit sharing based on taxable profit, possible union discussion and if needed communication with statutory auditors. In specific circumstances, we can approach tax authorities on an anonymous basis to consider settlement opportunities.
Transformation of tax organizations :
Tax organization must adapt and be agile in the post-Covid context. International and market environment need to be considered consider, as well as analyzing the best market practice. In medium-sized groups, the matter of how to use temporary resources and determining the right long-term profile are key. In this respect we may, for instance, support on a temp basis groups that are part of major reorganizations or M&A/PMI operations, and open our contacts to help selecting people who will be joining the group long term.