Latest publications
Leaders League ranking 2024
Leaders League 2024 Michelangelo is listed for the third year running in the following categories: Litigation – « Recommended ». » – Law firm France 2024
Leaders League ranking 2024
Leaders League 2024 Michelangelo is listed for the third year running in the following categories: Litigation – « Recommended ». » – Law firm France 2024
Private: Tax regime for cryptocurrencies: update following the adoption of the 2022 French Finance Act
Many companies offer their executives and/or employees share acquisition schemes known as “management packages”.
Management packages: vigilance is still required
Many companies offer their executives and/or employees share acquisition schemes known as “management packages”.
Hierarchical recourse: two separate guarantees during and after the audit
The hierarchical appeal is intended for taxpayers who encounter difficulties:
– during the course of the accounting audit; or
– during the contradictory examination of the personal tax situation.
Corporate Taxation
Recalibrating cross-border tax and wealth structures for France after recent regulatory shifts
As of August 27, 2026, French cross-border tax and wealth structuring has entered a period of accelerated legal and administrative change. Multinational tax rules (notably the OECD/EU Global Minimum Tax), […]
Practical defenses and holding adjustments for international assets facing recent French fiscal reforms
The wave of French fiscal reforms enacted and clarified between 2024 and 2026 has materially altered the compliance, enforcement and substantive tax positions that matter to non-residents and multinational groups […]
What in-house counsel should check now after reporting deadline extensions and crypto regime shifts
In-house counsel face a period of converging shifts: several filing deadlines have seen temporary extensions or clarified timing, while crypto regulatory and tax regimes across jurisdictions continue to crystallize. This […]
Practical steps to secure cross-jurisdictional holdings and property in France after recent fiscal reforms
France’s tax landscape has evolved significantly since 2023 with a series of international and domestic measures that materially affect cross‑border owners of companies and real estate. Multinationals, holding companies and […]
How recent fiscal reforms in France reshape planning for non-resident property owners and multinational groups
This article examines non-resident property taxation France in light of the most recent French fiscal reforms and supranational developments up to August 13, 2026. It focuses on measures that materially […]
Practical fiscal compliance and defense playbook for senior professionals managing offshore holdings
Senior executives, corporate groups and high‑net‑worth non‑residents face an evolving enforcement environment for offshore holdings. This practical playbook condenses recent international developments, compliance obligations and defence tactics into operational steps […]
Safeguarding cross-border wealth: audit defenses and fiscal structuring for mobile executives
Cross-border executives and high-net-worth non-residents face an intensified compliance and enforcement landscape. Recent multilateral developments have increased automatic information flows and introduced new minimum-tax rules that both corporate groups and […]
MiCA authorisation and GloBE reporting: a multijurisdictional compliance checklist for advisers
The concurrent rollout of the EU Markets in Crypto-Assets Regulation (MiCA) and the OECD-led Global Anti-Base Erosion (GloBE) framework (Pillar Two) has created a dense compliance landscape for groups active […]
Practical defenses for international wealth and corporate holdings facing tightened fiscal compliance
In an era of unprecedented tax transparency and cross‑border enforcement, holders of international wealth and corporate holdings face a shifting compliance landscape. Practical defenses must therefore combine careful legal structuring […]
What executives should do now to protect international wealth after recent French fiscal shifts
Executives with cross-border holdings must reassess exposure after a series of fiscal changes in France embedded in the 2026 Finance Law and subsequent parliamentary amendments. Recent debates and enacted measures […]
Conventions
Analysis
Analysis of Withholding Taxes on Companies in Ireland
Understanding withholding tax on dividends, interest, royalties and capital gains in Ireland. We analyze the details of restrictions, exemptions and reporting obligations for businesses.