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
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 […]
Navigating recent fiscal and residency shifts for internationally mobile executives with France ties
The international mobility of senior executives increasingly collides with evolving fiscal and residency rules in France and abroad. This article summarises recent developments and practical implications for executives with French […]
Practical measures for mobile owners facing new European fiscal and reporting regimes
European fiscal and reporting rules have evolved rapidly in the last three years. Multilateral initiatives (the OECD Pillar Two minimum tax), EU administrative cooperation updates (DAC6,DAC9), and sectoral frameworks for […]
After MiCA and recent finance-law moves: what international owners should check in France’s tax landscape
International owners with exposure to French assets or French-group entities are operating in a more complex intersection of regulatory and tax change than in recent years. The simultaneous arrival of […]
Securing international holdings and corporate resilience amid France’s evolving fiscal and digital-asset rules
France’s fiscal and regulatory landscape for cross-border groups and non-resident wealth has evolved rapidly over the last three years, driven by EU-level measures and domestic Finance Acts. Companies and high-net-worth […]
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 […]
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.