Tax Law.

Structuring M&A transactions.

We assist our clients in the acquisition or sale of companies with the negotiation, the technical tax analysis of the target and the structuring of the transaction. We deal with all tax aspects of mergers, demergers, partial demergers, transfers of headquarters, share exchanges and contributions of branches of activity.

We carefully draft or revise the tax declarations and warranties included in the share transfer agreements, taking into account the conclusions of our analysis following the tax due diligence performed by us.

An internal reorganization of the target is often necessary prior to the transaction, the accounting and tax aspects of which should not be neglected. We particularly draw our clients’ attention to the conditions of application of the tax neutrality regime for reorganization operations, the fate of the tax latencies of the companies concerned and the real estate assets held.

We regularly submit these operations to the Advance Tax Ruling Service (ATRS) in order to provide our clients with legal certainty regarding the recommended tax treatment. Obtaining a ruling will avoid any subsequent questioning of the transaction by the tax authorities in the event of an audit.

We work in close collaboration with the M&A team.

For more information, please contact the partner in charge of structuring M&A transactions : Didier Grégoire.