№ 05

Tax.

Overview

The firm advises on the tax dimension of cross-border wealth, business holdings, and major transactions. Engagements rarely concern tax in isolation — tax structuring is almost always one component of a broader matter that also involves corporate, real estate, or estate planning work. The firm's tax advice is therefore integrated with the rest of the engagement rather than delivered as a stand-alone product.

The firm does not prepare tax returns or routine compliance filings. It works alongside the client's appointed accountants and tax-return preparers, contributing the structuring view and the cross-border analysis that those professionals do not typically provide.

§ A · Scope

Six recurring workstreams.

Practice 05
I

Cross-border tax structuring

Analysis and design of holding architectures with attention to treaty access, beneficial-ownership requirements, and the anti-abuse provisions that European and American treaties now routinely contain.

II

Wealth-tax obligations

Compliance with French IFI, Swiss cantonal wealth tax, Spanish patrimonio, and equivalent regimes, including the structuring choices that determine the base and the assessment year by year.

III

Tax residency and exit planning

Analysis of tax residency under domestic and treaty rules, and structuring of relocation between jurisdictions — including the exit-tax exposures that several European jurisdictions now apply on departure.

IV

Audit and dispute management

Coordination of responses to tax-authority enquiries and audits, negotiation of settlements, and preparation of the file for litigation where it cannot be avoided.

V

Reporting and disclosure

Advice on FATCA, CRS, DAC6, and equivalent reporting obligations, and on the consequences of disclosure failures or inconsistencies between filings made in different jurisdictions.

VI

Transactional tax

Tax analysis of acquisitions, disposals, and restructurings — including the deductibility of acquisition financing, the tax treatment of earn-outs, and the consequences of post-closing reorganisations.

§ B · Approach

A senior partner leads each engagement.

Each file
How we work

Tax engagements are led directly by a senior partner with sustained practice in the cross-border tax architecture of the firm's working jurisdictions. Where local tax advice is required — French CGI specifics, Swiss cantonal practice, Italian IRES interpretation — the firm coordinates with locally admitted tax counsel and integrates their input into the overall analysis. The firm does not provide opinions on tax positions for which a reasoned legal view cannot be supported. Where a client's preferred outcome cannot be defended on the merits, the firm says so directly.