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
How executives can shore up overseas holdings against tighter fiscal scrutiny and minimum-rate rules in France
France has sharpened both its substantive tax rules and its enforcement posture toward foreign affiliates and cross-border groups. Since transposing the EU Pillar Two Directive into domestic law, French authorities […]
Strengthening cross-border wealth and holding structures ahead of France’s finance law and global minimum tax rollout
The convergence of France’s Loi de finances pour 2026 and the OECD’s global minimum tax framework under Pillar Two represents one of the most significant legislative inflection points for cross-border […]
Practical steps to protect mobile wealth and property amid new compliance pressures
Owners of cross-border assets face a rapidly evolving compliance landscape: new automatic-exchange standards for crypto and digital products, expanded beneficial‑ownership and AML transparency measures in multiple jurisdictions, and continuing international […]
Practical steps to protect assets and corporate structures under evolving international tax rules
The international tax landscape is undergoing its most profound transformation in decades. Driven by the OECD’s two-pillar reform framework, the proliferation of anti-avoidance rules, and the rapid expansion of cross-border […]
Mitigating risks to mobile wealth and corporate entities after recent OECD and EU tax reforms
The international tax landscape has entered a new phase of enforcement and information exchange following a series of OECD and European Union reforms. Multinational enterprises, high‑net‑worth individuals and the service […]
How mobile executives should shore up international holdings ahead of tougher reporting and enforcement
Global reporting and enforcement for cross-border assets have crystallised into a denser regulatory reality. Between the EU’s DAC8, the OECD’s Crypto-Asset Reporting Framework (CARF) and the ongoing roll-out of the […]
Navigating compliance and structuring risks in France’s evolving fiscal regime
France’s tax environment has undergone material change in recent years, driven by international reforms, EU coordination and reinforced domestic enforcement. For corporate groups, executives and non-resident high-net-worth individuals, these shifts […]
Practical fiscal planning for property owners and mobile professionals amid recent domestic and multijurisdictional reforms
Owners of real property and professionals whose work crosses borders face a rapidly evolving tax environment. Recent multilateral initiatives, supranational guidance and a wave of domestic reforms have altered both […]
How international owners can shore up holding structures as new domestic rules and global minimum reporting take effect
As domestic Pillar Two implementations and multilateral reporting processes have come into force, international owners of holding structures face a new landscape of top-up taxes, information returns and potential adjustments […]
Practical steps to reorganize cross-border structures and stay audit-ready under new international rules
The international tax landscape has been reshaped in recent years by the OECD/G20 two‑pillar initiative, new EU measures and parallel domestic implementations. Multinational groups and wealthy non‑resident individuals face new […]
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.