Practice Areas

Our lawyers have particularly renowned expertise in relation to tax audits and high-stakes tax controversies, enabling them to assist French and international clients at all stages, whether in initial discussions and/or negotiations with the French Tax Authorities concerning tax audits or advising in relation to dawn raids, or defending cases before French or supranational courts and institutions (ECHR, CJEU), or challenging administrative decisions (notably by applications to administrative courts to set aside a decision in the context of recours pour excès de pouvoir procedures) or advising on questions of constitutionality, as well as defending clients in criminal proceedings involving tax fraud.

The team notably assists several major international, particularly US-based, companies, in connection with tax controversy matters before the French Tax Authorities, relating to issues of tax treatment in France of cross-border flows and income, allocation of value or alleged permanent establishments. The tax team regularly submits requests for Advance Pricing Agreements and puts in place Mutual Agreement Procedures for the elimination of double taxation on behalf of its clients.

The team is also noted for its unique ability to bring together multi-disciplinary litigation teams, including notably lawyers from the firm’s white-collar criminal defence and public law departments.