Group structuring & management feesTax lawyers in Bordeaux, Paris and Hossegor
Structuring groups of companies and putting management fee arrangements in place are major tax and financial issues for businesses. An optimal organisation makes it possible to streamline governance, optimise taxation and secure intra-group flows.
Our firm, which specialises in corporate taxation and group strategy, assists its clients in designing, implementing and monitoring group structures and management fee agreements, in order to ensure compliance with tax legislation and secure the relationships between companies.
Our areas of intervention
1 – Structure analysis and feasibility
A preliminary study is essential to secure transactions and optimise tax outcomes:
- Analysis of the group’s existing structure and of the legal links between companies;
- Identification of financial flows and centralisation needs;
- Assessment of the tax and financial impact of management fees;
- Definition of a structuring strategy suited to the group’s objectives;
- Anticipation of tax and litigation risks.
2 – Implementing management fees
Management fees must be implemented in accordance with strict legal and tax criteria:
- Drafting of management fee agreements that comply with the legislation;
- Determination of the calculation basis and invoicing terms;
- Substantiation of the services rendered and appropriate documentation;
- Coordination with the companies’ accounting and finance departments;
- Assistance in dealings with the tax authorities.
3 – Tax optimisation of intra-group flows
The organisation of financial flows within a group must reconcile optimisation and compliance:
- Definition of the remuneration policy for intra-group services;
- Tax optimisation of management fees and reduction of the risk of tax reassessment;
- Analysis of the impact on corporate income tax and VAT;
- Implementation of mechanisms suited to the relationships between companies.
4 – Monitoring and compliance
Regular monitoring secures the structure and avoids any tax risk:
- Review of the consistency and substantiation of management fees;
- Monitoring of legislative and case-law developments;
- Assistance in the event of a tax audit;
- Adapting agreements and adjusting practices over time.
5 – Strategic advice and long-term support
Beyond the initial implementation, our support aims to secure decisions and anticipate developments:
- Advice on the group’s future structure;
- Analysis of merger, acquisition or disposal transactions;
- Ongoing optimisation of intra-group financial flows;
- Definition of sustainable governance and management fee policies.
A confidential, rigorous, and tailored approach
Every structuring and management fee project calls for a specific response. Our approach is based on:
- A personalised approach, tailored to the size, composition and objectives of the group;
- A thorough understanding of the applicable tax and legal rules;
- A rigorous strategy, combining tax optimisation and legal certainty;
- Absolute confidentiality, suited to sensitive and strategic matters.
A trusted partner for group structuring and the management of intra-group flows
We act as a strategic partner to our clients, securing the group’s structure, optimising financial flows and protecting the company’s interests in a demanding and constantly changing tax environment.
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