(Corporation tax, transfer pricing, business restructuring, VAT, tax consolidation)
When you are running your company, common questions also arise about whether a provision can be deducted for tax purposes, the deductibility of an expense in a contract for management fees or other complex transactions.
The tax basis of companies also impose regular questioning of whether the company has forgotten to invoice a company in the group for any sort of advantages obtained free of charge and more typically for asset transactions, the guarantee deposits provided or other operations carried out with no negotiation on the price since they are intra-group operations.
In so doing, these group operations may lead us to envisage together the construction of a tax consolidation scope, in order to limit the disadvantages just mentioned.
The complexity of your operations, or the fact that you are carrying out new ones, or are inventing new products will also lead you to wonder how to apply VAT and at what rate.
When your company grows, you may envisage agreements with partners which could be expressed as mergers, partial asset contributions, universal asset transfers and any other of consolidation or deconsolidation operation.
Lastly, if you intervene in several countries, you will necessarily have to fix the prices of the goods and services, or even of the financing, which takes place between all the entities of the group. These issues have important repercussions in terms of taxation and generically come under the designation of “transfer pricing”. Establishments in more than one country may also lead you to use exchange rate or interest rate hedging, the fiscal and accounting rules of which require a certain amount of solid legal analysis which we can provide you with.