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
Protecting executives’ overseas property and income in France amid recent finance law and global minimum rules
France’s tax landscape for high‑net‑worth individuals and mobile executives has evolved rapidly since the global agreement on a 15% minimum tax and the transposition of the EU minimum tax into […]
Managing executive exposure as France tightens crypto rules, minimum-tax reporting and residency checks
France has moved decisively in 2025,2026 to close regulatory gaps around crypto activity, cross-border tax transparency and minimum-tax enforcement. For corporate executives and high‑net‑worth individuals, this convergence of MiCA implementation, […]
Tax defenses and structuring for international executives amid France’s MiCA, DAC8 and Pillar Two roll-outs
France’s recent regulatory developments, the EU’s DAC8 crypto reporting rules, the Market in Crypto-Assets (MiCA) regime and the global Pillar Two minimum tax framework, materially affect tax exposure and compliance […]
How France’s tax measures and crypto licensing overhaul change risks for cross-border wealth holders
On July 2, 2026, cross-border holders of wealth,particularly high‑net‑worth individuals and family offices with crypto exposures,face a materially different legal and tax landscape in France and the EU than they […]
What global leaders need to know to protect overseas holdings and meet new reporting duties
Global transparency measures and new reporting duties introduced since 2023 have materially changed the risk and compliance landscape for overseas holdings. Corporate groups, executives and non-resident clients must now reconcile […]
From residence rules to reporting traps: a practical checklist for executives with foreign property
Executives holding foreign real estate face an expanding web of residency tests, tax bases and cross-border reporting obligations. Failure to identify applicable tax residency rules or to meet disclosure duties […]
Navigating the June 30 compliance rush: essentials for global groups and high-net-worth owners
The June 30 compliance rush is the immediate reality for many multinational groups and high‑net‑worth owners in 2026. With the first GloBE Information Return (GIR) filing and a cluster of […]
What to prioritize when restructuring international holdings after recent EU and domestic fiscal reforms
Recent EU and domestic fiscal reforms have materially changed the compliance and economic calculus for multinational groups and non-resident investors. Policymakers have moved from high-level policy consensus to concrete rules, […]
France’s tax shake-up: practical steps for executives with international assets
As of 15 June 2026, France has implemented a set of tax measures in the 2026 Finance Act that materially affect executives and corporate groups holding assets across borders. These […]
How executives can protect international wealth and property amid recent fiscal and reporting reforms
Executives and high-net-worth individuals holding cross-border assets face a rapidly changing compliance landscape. A wave of international fiscal and reporting reforms, from the OECD’s expanded Common Reporting Standard and Crypto-Asset […]
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.