Tax management for corporations and corporate executives

MICHEL-ANGE assists its clients in structuring and restructuring operations (acquisitions/disposals, contributions of assets, mergers, setting up of tax integrated groups). Its assistance includes tax audits as well as the analysis of tax consequences of the various business transactions intended (drafting of structure memoranda) or contacts with the tax authorities (tax approval or tax rescripts negotiation). Its scope of intervention covers all taxes, including:

• Corporate income tax;
• Registration fees;
• Local taxes;
• Value added tax (VAT);
• Withholding of tax at source.

MICHEL-ANGE assists cross-border groups in their constant tax issues (tax structuring of the activity operated from France, tax optimisation of incoming and outgoing flows, tax incedences of the existence of a permanent establishment in France, consequences of cross-border restructuring operations).

MICHEL-ANGE also assists corporate executives (French resident for tax purposes or non- residents) in setting up management packages and, more generally, in structuring their incomes.