Arfé Avocats supports companies to help them best manage the tax consequences of their transactions.
The firm also regularly conducts acquisition audits to help purchasers anticipate tax risks linked to the acquisition of a target and thereby better negotiate the purchase price and/or the SPA.
We assist companies in determining the tax treatment applicable to their day‑to‑day operations and in assessing the opportunity to adopt specific tax elections: implementation of a tax consolidation regime, service‑agreement arrangements, and so on.
We also help companies optimizing the tax consequences of restructuring operations (merger, TUP, partial asset contribution, etc.) and acquisitions (LBO, OBO, etc.). Such transactions generate numerous tax frictions that should be minimized so that the operations remain viable.
The firm regularly requests binding rulings from the tax administration to help companies secure their tax positions where the law is ambiguous or insufficiently precise for their situation.
Tax neutrality of mergers and acquisitions
Transfer of tax losses
Group tax consolidation
Tax approvals
Binding rulings
Compliance with reporting obligations
The firm undertakes numerous tax due diligences in the context of acquisitions. We examine target companies’ tax returns and elections in detail to determine whether there are tax risks likely to affect the purchase price or the SPA.
Our work is systematically presented in a detailed reports enabling you to quickly integrate the main points of concern arising from our conclusions.
Tax audits
Assistance drafting the tax clauses of the SPA
Structuring memoranda
