Fiscalité

Tax Law

In an environment of globalization and competition, fail-safe tax optimization is an asset both for the company and its directors and shareholders.

Gramond & Partners decided to develop a dedicated department with the arrival of Marianne Grignard Gardner as partner in 2008.

References

A cross-disciplinary service within the Firm, the Tax Law department works with medium-sized and multi-national companies in all the business lines (industry, services, finance).

Practice

Gramond & Partners offers its clients, companies or individuals, assistance in their special and everyday projects.

In the context of its specific activity, the Firm assists its clients in their restructuring and acquisition operations (partial business transfer, merger, demerger, LBO...) by:

  • offering and drafting tax structuring for capital financing operations
  • conducting tax audits of target companies as well as “Vendor Due Diligence” reports
  • validating the tax implications of “management packages” (including tax aspects related to using stock warrants, bonus shares, equity warrants, stock options, etc.)
  • studying the tax consequences and preferred solutions for directors and shareholders with respect to their personal taxation (income tax and wealth tax)

On a daily basis, the Firm’s action consists of:

  • reviewing various tax returns within the company and validating the principles used to determine tax bases (corporate tax, business tax, VAT, etc.)
  • implementing tax consolidated regim
  • the choices to be made in terms of international mobility for employees within a group (impatriation and expatriation policy, split payroll...)
  • validating the principles applied with regards to transfer pricing within a group
  • analyzing tax rules to apply in the presence of international flows (dividends, interest, license fees, royalties) and foreign companies established in France (arbitration between the establishment as a subsidiary or as a branch, issues related to the notion of permanent establishment...)

Lastly, the Firm assists its clients with pre-litigation (assistance with tax audits) and litigation (referral to the administrative Court ant the Court of appeal), proceedings with regards to tax authorities. Beside litigation, Gramond & Partners also negociate with the Tax Administration in connection with requests for advance rulings or tax approvals.

Contacts

Phone : +33 1 56 68 88 90

Marianne Grignard-Gardner  - Partner
>> mgg@gramond-associes.com