Tax audits and
litigations in France
Our team of tax lawyers has over 20 years' experience in tax audits and tax litigation in France
Nouvion Avocats has been ranked as one of Paris' leading tax audits and litigation firms since 2010, providing companies and individual clients with solid technical expertise in both tax and procedural matters.
Pragmatic and efficient, Nouvion Avocats offers relevant
solutions for resolving tax disputes.
First contact
Nouvion Avocats offer a first consultation with one of our tax lawyers. The consultation will be either a face-to-face meeting, a telephone conference or by email.
The Benefits
The purpose of this consultation is to enable you to set out the background to your tax audit / tax litigation issues to help you decide whether to instruct one of our specialist lawyers to assist you.
During the consultation, we will establish whether your issue is something that the firm can assist with and if possible our initial observations and/or what the initial costs will be for us to deal with the matter.
Contact us by phone or email detailing your issue (e.g. information demand from the French administration, tax search, corporate and personal tax audit, tax litigation) attaching relevant information:
15 Q&A for foreign companies or individuals facing a tax audit in France
Please find below answers to the key questions usually raised by foreign companies or individuals facing a tax audit in France.
1. Examples of triggers of a tax audit in France
Foreign companies may be subject to several administrative controls in France, even if they operate in France temporarily (e.g., construction sites or works) or from a place located outside French territory (e.g., internet distance sales or operations carried out through a French agent - third party or even subsidiary).
Usually, works carried out "on site" on French territory can first entail an audit from the labour inspection on the conditions / authorisations of the personnel, which itself can lead to an URSSAF audit (the French administration in charge of recovering social contributions), but also to a tax audit, to ensure that the foreign company pays its taxes in France.
It is also now common in internet distance sales (particularly via marketplace platforms operating in France) for a tax audit of the foreign company to be initiated after cross-referencing of tax returns of the marketplace customers or following a tax audit of the French marketplace itself.
Although the French tax authorities have not always been successful in this regard, recent audits have successfully characterised permanent establishments of foreign companies in their French subsidiaries acting as their dependent agents :
- In a Conversant case (rendered by the Conseil d’Etat on 1 December 2020), the Conseil d’Etat judged that the French subsidiary acted as the dependent agent of its Irish parent company (subject to a 12.5% CIT rate) because even if it did not formally conclude contracts in the name of the Irish company, it decided on transactions which the Irish company merely ratified » ;
- In a similar dispute involving Google France (challenged by the French tax authorities as acting as a dependent agent of Google Ireland, therefore characterising a French permanent establishment of it), even if Google was successful before the first instance and appeal courts (in July 2017 and April 2019), Google finally chose to settle by signing a “convention judiciaire d’intérêt public” (Judicial Agreement in the Public Interest) with the French State for an amount of €500 million plus another agreement with the French tax authorities in the amount of €465 million. The possibility of signing a CJIP “convention judiciaire d’intérêt public“ was introduced by Article 22 of Law No. 2016-1691 of 9 December 2016 on transparency and the fight against corruption. By Law No. 2018-898 of 23 October 2018 the law was extended to cover cases of tax evasion. According to the CJIP, legal actions can be ended in return for the payment of a fine.
The economic scheme and the factual situation must be rigorously analysed. It is not only a question of legal qualification.
Recently, the Conseil d'Etat characterised the (taxable) permanent establishment in France of a Cypriot company through the intermediary of a French dependent agent (even though this argument was not invoked by the tax authorities). It was considered that " the management and the administrative and operational coordination of the employees placed at the disposal " of a French company were ensured exclusively by " personnel installed in France placed at the disposal of the French company, the personnel of the head office intervening only to receive the contractual documents and to issue notices of invitations to tender " (CE 8th and 3rd chambers, 5 July 2022, no. 458293, Société Bouygues TP).
For individuals, a tax audit may be triggered by various facts or circumstances: a documentary audit of declarations revealing anomalies, information obtained by the tax authorities that does not tally with declarations, suspicious major banking movements, significant variations in declared income from one year to the next, a lifestyle that does not correspond to declared income, major events involving significant asset transfers (intra-family property sales, inheritances, gifts), a change of residence, and of course whistle-blowing.
Our dedicated team of tax lawyers, fluent in French, English and Spanish, assists foreign companies on a day-to-day basis with their tax audits and disputes in France.
We are at your service to assist and advise you.
2. Have you been subjected to a tax search procedure (perquisition fiscale) in France?
The tax agents have, according to article L16 B of the French Tax Procedures Code (Livre des procédures fiscales - LPF), a right of visit and seizure (perquisition fiscale) in all places, even private, for the investigation of infringements in tax matters.
On request, the administration first applies to the French judge to authorise the procedure. The authorisation of the judge is granted only where there are presumptions that the foreign company is avoiding establishment or payment of taxes on revenues or incomes or of value-added tax (VAT).
It is a special and complex procedure, a real weapon at the disposal of the Authorities.It must be distinguished from the procedure for verification of financial records (“procédure de vérification de comptabilité”, art. L. 47 of LPF) and from the investigation procedure referred to in article L. 80 F of that code, as well as from the criminal search provided for by the provisions of articles 56, 67 and 96 of the French Code of Criminal Procedure. Indeed, the only purpose of the domiciliary visit procedure (visite domiciliaire) is to allow, under the control of the judicial authority, the sole taking or seizure of documents directly related to the fraud being investigated, without involving any sophisticated control or interrogation, the latter being limited to the indication of the location of the documents.
The domiciliary visit does not in itself constitute a tax audit. It is an autonomous procedure that the administration can implement prior to and as an option to an audit.
Nevertheless, visits and seizures under article L.16 B of the LPF are almost always a preliminary to a tax audit and to the seizure, following adjustments, of the Commission for Tax Infractions (Commission des infractions fiscales) with a view to a penal charge for tax fraud (article 1741 of the General Tax Code).
The tax search may only occur between 6 am and 9 pm. Tax agents must be accompanied by a judicial police officer. They may search in all places (business premises, construction sites, private homes, etc.) for items and documents relating to fraudulent acts, whatever the medium. The search is carried out in the presence of the occupant of the premises or his or her representative. If this is not possible, the judicial police officer shall request two witnesses chosen from outside the persons under his or her authority or that of the tax authorities.
At the end of the tax search, a report of the procedure followed and the entirety of the documents seized is given to the taxpayer.
Two appeals may be lodged against this tax search procedure (perquisition fiscale): (i) one against the visit and seizure operations “on site”, to be submitted within 15 days from the delivery or receipt of the report, and (ii) the other against the order of the judge who authorised the tax search, to be submitted within 15 days from the formal notification of the order.
In any case, whatever the prejudicial character of the seized documents, it is strongly recommended to take legal action to challenge the presumptions of fraud of the administration and more generally to present the position of the company (productions of suitable justifications and defence arguments) in anticipation of the likely implementation of a more complete procedure.
3. Have you received a request to regularize a bank account held abroad?
As part of the measures taken in the 90s to liberalize exchange controls, the French legislator introduced an obligation to declare bank accounts opened, held, used or closed abroad (CGI art. 1649 A).
This obligation is punishable by :
- a fixed fine €1,500 per undeclared account, in the general case; the fine is increased to €10,000 per undeclared account when the obligation to declare concerns a State or territory which has not signed an administrative assistance agreement with France to combat tax fraud and tax evasion, allowing access to banking information; this fine is applicable in the event of failure to file the declaration or in the event of incomplete declaration, and for each non-prescribed year in respect of which the infringement is revealed (BOI-CF-INF-20-10-50 n° 20) ;
- implementation of a statutory presumption that sums, securities or assets transferred to or from abroad via undeclared accounts constitute taxable income, unless the taxpayer can prove otherwise;
- a surcharge of 80% in addition to interest for late payment, tax reassessed are subject to a surcharge of 80%, which applies to duties due in the event of rectification due to sums appearing or having appeared in one or more accounts that should have been declared. The amount of this increase may not be less than the fixed fine of €1,500 or €10,000;
- refusal to set off certain losses.
The administration's right of recovery extends to the end of the tenth year following the year in respect of which the tax is due, when accounts opened, held, used or closed outside France have not been declared. However, this extension does not apply where the taxpayer can prove that the total credit balances of his foreign accounts did not exceed €50,000 at any time during the year in respect of which the tax return was due.
4. Have you been subjected to a tax audit and just received a reassessment notice (proposition de rectification)?
The French tax authorities may, according to article L 13 of the LPF, carry out a tax audit of your company (initiated by the formal notification of a verification notice – avis de vérification - to which is attached a charter of the rights and obligations of the verified taxpayer).
Although the audit is usually carried out at the head office of the company, for foreign companies with no physical presence in France the audit is carried out mainly through the exercise of the right of communication of the tax administration, to the company itself, to third parties (clients, banks, marketplaces, agents, etc.), but also very often by the implementation of the international administrative assistance of the tax authorities of the State where the company's head office is located.
Due to its very wide Double Tax Agreement network, the French administration usually obtains communication of information through this channel. When it plans to make a reassessment, the administration first sends you a “proposal of reassessment” (proposition de rectification).
You have 30 days (extended to 60 days on request) to communicate your comments. Then, the administration notifies its “response to the taxpayer's comments” (réponse aux observations du contribuable) indicating whether or not it intends to maintain the proposed reassessments.
In case of disagreement between you and the tax administration, you may also request an interview with the auditors’ supervisor, or file an action with a departmental commission (entitled to issue opinions on the reassessments - generally followed by the administration) if your disagreement persists despite these exchanges. These actions must be exercised before the issuance of the formal recovery notice (see below).
At the end of the audit procedure, if the reassessments are maintained, a formal recovery notice (avis de mise en recouvrement – AMR) will be issued. After such issuance a litigation procedure may be initiated (see below).
5. You have not responded to the French tax administration’s requests, and it has implemented the automatic self-assessment procedure (procédure d’imposition d’office)?
The reassessment procedure is, in principle, contradictory and is characterised by a dialogue between the administration and the taxpayer.
However, in the absence of timely declarations or a response to requests for clarification and justification, the administration may implement the self-assessment procedure which allows it to assess the taxes due on the basis of the only information available to it. The burden of proof is then reversed, and the tax payer has to prove that the reassessed amounts are exaggerated. This unilateral procedure also has the effect of depriving the taxpayer of his or her right to refer the matter to the auditors’ supervisor.
It should be noted that the taxpayer can be subject to an automatic self-assessment procedure only after the administration has given him formal notice to regularise his situation (unless he has also failed to comply with his obligation to make himself known to a Centre for Company Formalities).
If the company refuses to respond to the requests of the administration, it is also exposed to the consequences of an opposition to tax audit (penalty of 100%, in particular).
It is therefore strongly recommended to cooperate with requests from the tax administration and to establish a constructive dialogue.
6. Has the French tax administration applied a penalty of 80% for the exercise of a concealed activity (activité occulte)?
As regards foreign companies which did not file any return in France (this is the case when a permanent establishment has been characterised), it is now very common for the French tax administration to apply the penalty of 80% (article 1728-1.c of the CGI) for concealed activity on the grounds that the company has not disclosed its activity to a French Centre for Company Formalities or to the registry of the French Commercial Court.
In certain situations, this penalty of 80% appears challengeable. This is the case, in particular, in the context of proceedings against a foreign company duly registered in the EU which has already paid its income taxes that the French administration intends to impose in France. It is therefore appropriate to challenge this characterisation of a concealed activity and the corresponding application of the penalty of 80%. The case law on this matter focuses on the good faith of the taxpayer by crystalising the debate on the intentional nature of the dissimulation.
The case law on this matter focuses on the good faith of the taxpayer by crystalising the debate on the intentional nature of the dissimulation.
The characterisation of a concealed activity (e.g., a non-declared permanent establishment) is a particularly perilous situation since the statute of limitations is extended to 10 years in this case (art. 169 par. 2 of LPF).
7. How to litigate before the Court against the tax reassessments maintained?
When the administration maintains the reassessments and issues a formal recovery notice (avis de mise en recouvrement - AMR), you have 3 years (until 31 December of the third year following the year in which the AMR was issued) in which to challenge it.
In order to challenge the amounts recovered, you must send the administration a preliminary claim (réclamation contentieuse). In the event of a formal rejection answer notified to you, you have 2 months to file a claim before the competent administrative tribunal. After a period of silence of 6 months, the absence of a response from the tax administration shall be deemed to be a rejection of your claim.
The litigation procedure is quite long. On average, it takes at least one year to obtain a decision of the administrative tribunal, then another one to two years in case of appeal, and finally at least one more year to obtain a decision of the Conseil d’Etat.
8. In the event of a challenge to the taxation before the administrative tribunal, is it possible to obtain a suspension of payment of the reassessed taxes until the dispute is resolved?
Litigation claims do not, by themselves, constitute suspensions of payment. In principle, in case of dispute, you must therefore pay the amount of the principal sum due and that of the fines or penalties applied within the statutory period allowed.
However, the law allows you to request a suspension of payment. For this purpose, it is mandatory to include a formal request for suspension of payment in your claim. This suspension of payment is a right.
However, the administration will ask you to provide accurate guarantees. In the absence of guarantees, or if the guarantees offered are considered insufficient, the administration may take precautionary measures for the contested taxes (conservatory seizures ...) In this case, the taxpayer may still ask the judge for interim suspension (“référé-suspension”) provided for in Article L. 521-1 of the Code of Administrative Justice for the recovery of taxes.
If the suspension of payment is granted but the taxpayer does not ultimately win the case at court, late payment interest will have to be paid.
First contact
Nouvion Avocats offer a first consultation with one of our tax lawyers. The consultation will be either a face-to-face meeting, a telephone conference or by email.
The Benefits
The purpose of this consultation is to enable you to set out the background to your tax audit / tax litigation issues to help you decide whether to instruct one of our specialist lawyers to assist you.
During the consultation, we will establish whether your issue is something that the firm can assist with and if possible our initial observations and/or what the initial costs will be for us to deal with the matter.
Contact us by phone or email detailing your issue (e.g. information demand from the French administration, tax search, corporate and personal tax audit, tax litigation) attaching relevant information:
9. I am subject to double taxation in France and in my state of residence due to a difference in interpretation of the tax treaty between those two states
France has signed around 120 bilateral tax treaties, allowing the taxpayer to initiate a mutual agreement procedure, independently of the internal appeal procedures, when he believes that he has been subject to double taxation or taxation not in accordance with the treaty signed between France and the state in question, within a period of 3 years (this period may vary according to the treaties) from the first notification of the measure leading to double taxation or taxation not in accordance with the treaty concerned. The request must be made in writing and expressly to the competent authority of the state of which the aggrieved taxpayer is a resident.
This procedure implies that the two states that are party to the agreement try to find a satisfactory solution, without being under any obligation to achieve a result.
Although this procedure does not oblige the states to reach an agreement resolving the dispute, in 2021, according to an OECD colloquium on legal certainty in tax matters, in 77% of the cases, the mutual agreement procedures were closed and resolved the issue at dispute, and only 2% of the cases were not resolved by an agreement.
... If the amicable procedure fails, what other options are available?
For agreements that have been modified by a multilateral instrument, such as that between France and Austria, for example, it is provided that in the absence of a mutual agreement, a binding arbitration procedure may be introduced. States are invited to allow that, after an initial phase involving a mutual agreement procedure which may not exceed two years, issues not resolved by mutual agreement may be submitted to arbitration if the taxpayer so requests, in writing, at any time after the expiry of the two-year period mentioned above.
At the European Union level, the European Arbitration Convention provides for a procedure for the elimination of double taxation in transfer pricing matters. It also implies following up on a mutual agreement procedure that has failed after two years.
Two conditions must be met, however: the claim must appear to be well-founded and the state must not be able to provide a satisfactory solution on its own.
On the other hand, the European Arbitration Convention provides for broader referral procedures than those provided for in bilateral tax treaties, since the company may refer the matter to the competent authority of the state that carried out the adjustment or to that of the company that is subject to double taxation.
10. When is a case subject to automatic criminal prosecution?
The tax administration is required to report to the State Attorney the facts that have led to the application of the following provisions to dues in excess of €100,000:
- 1. Either the 100% increase provided for in case of opposition to an audit (CGI, art.1732);
- Or the 80% surcharge provided for in various cases of concealed activities, abuse of rights, or fraudulent manoeuvres (CGI, art. 1728, 1, c, art. 1729, b and c, art. 1729-0, A, I or art. 1758, last paragraph);
- Or the 40% increase provided for in articles 1728 1 b or 1729 b and c of the CGI, when during the six calendar years preceding its application, the taxpayer has already been subject to the application of the above-mentioned increases or to a claim by the administration.
However, if the amount of the "interests at stake" is less than €100,000, criminal proceedings may still be initiated on the basis of a preliminary complaint by the tax authorities, after receiving the approval of the Commission for Fiscal Offences (Commission des infractions fiscales).
11. Is it possible to negotiate a settlement of the tax debt or payment by instalments?
A settlement with the tax administration, containing written commitments on both sides, may in principle only be agreed on the amount of penalties on direct taxes.
Upon request, the tax administration may accept an instalment plan, but in order to obtain it the foreign company will have to prove the existence of financial difficulties and give sufficient payment guarantees to the tax administration. The request must precisely describe the modalities of the instalment: notably the term (it cannot exceed two years) and the payment of a first significant instalment.
The possibility to sign a CJIP “convention judiciaire d’intérêt public” was introduced by Article 22 of Law No. 2016-1691 of 9 December 2016 on transparency and the fight against corruption. By Law No. 2018-898 of 23 October 2018, the law was extended to cover cases of tax evasion. According to the CJIP, legal actions can be ended in return for the payment of a fine.
12. Can I be refused a deduction of invoices issued by a company located in a privileged tax state?
The deduction in France of sums paid abroad may be refused in France, if the country of destination is a "privileged tax state" within the meaning of the terms of article 238 A of the CGI. In reality, it is not a question of considering the country as a whole, but of determining whether the recipient of the payment is subject to taxes on profits that are 40% lower than those for which it would have been liable under the conditions of ordinary law in France if it had been established there.
The burden of proof that the recipient of the remuneration in question is subject to a preferential tax regime lies with the tax authorities. The tax authorities must be able to provide detailed information relating not only to the tax rate applied, but also to all of the conditions under which activities comparable to those carried out by the recipient of the sums in question are taxed in the country where the recipient is domiciled or established.
If the tax authorities are able to provide such proof, then the deduction of those expenses is only allowed on the condition that the French debtor can establish that they correspond to genuine operations and that they are not abnormal or exaggerated.
Finally, it should be noted that these conditions for deduction are further tightened in the event that the sums are paid to beneficiaries established in one of the non-cooperative states or territories (ETNC).
13. The residence of my company abroad is contested because I am not currently taxed in my country of residence.
Bilateral tax treaties, following the OECD model, define a "resident of a Contracting State" as "any person who, under the laws of that state, is subject to tax in that state by reason of the person's domicile, residence, place of management or any other criterion of a similar nature".
The Conseil d'Etat interprets the condition of tax liability, set out in the provisions of the tax treaties defining the concept of resident of a Contracting State, as implying not only inclusion in the scope of application of the tax but also submission to the tax, understood as the absence of structural exemption.
The benefit of a tax treaty may therefore be denied to you if, in your State of residence, you are structurally exempt from tax.
Tax liability within the meaning of the provisions defining residence is not the same as actual payment of tax. It is sufficient that the person is liable to to tax without being structurally exempt from it for him to be considered as liable to tax in the conventional sense, as long as this liability entails a risk of double taxation which is not structurally ruled out and which, in principle, justifies the conventional protection, even if it has not actually materialised.
In a recent case law (CE 2 février 2022, no. 443018, Sté Observatoire d’économie appliqué), it was held that a Tunisian company with its head office in Tunis was only exempt from tax on profits from exports, but not on profits from activities carried out in Tunisia, even though it had not achieved any sales revenue on the local market during the period in question, and that it was therefore subject to corporate tax in Tunisia on the basis of its activities. The company should therefore be considered resident in Tunisia.
14. 3% tax on property: Do I have to justify the composition of the shareholding?
All French or foreign legal entities that own, directly or through an intermediary, one or more properties (or real rights over such properties) in France are liable for a tax equal to 3% of the market value of the properties in question (CGI, art. 990 D et seq.).
An exemption from this tax is provided for legal entities whose registered office is located in France, in the European Union or in a country that has signed an administrative assistance agreement with France to combat tax evasion and avoidance, and which fulfill declaratory obligations (CGI, article 990 E, 3° d), i.e. which communicate, or who undertake to provide the tax authorities with information concerning the associates (identity and address in particular), which will enable the authorities to subject the associates to wealth tax or free transfer tax on the transfer of shares (and, where applicable, capital gains tax).
According to case law, it is up to the taxpayer to provide evidence of the accuracy of his declaration, and the tax authorities do not have to prove the inaccuracy of the declaration, but must only demonstrate that the evidence provided is insufficient to prove it; the evidence provided must be dated prior to, or at least contemporary with, the date of the taxable event.
In order to ensure that the 3% tax exemption is justified, the tax authorities may ask the legal entity concerned to provide proof of the identity and address of its shareholders, partners or unitholders, and of the number of shares or rights held by each of them, by means of the necessary supporting document(s) (BOI-PAT-TPC-20-20 n° 570) ; Documents that can be used to substantiate this claim include:
- corporate documents filed with the courts or public services of the state or territory of residence of the entity in question, such as: extracts from the register of companies or equivalent, articles of association, corporate registers required under the company law of the country concerned (deliberations of shareholders' meetings and management bodies, minutes of general meetings, meetings of the board of directors or supervisory board, etc.);
- declarations filed with the tax authorities of the entity's country or territory of residence, where they provide such information;
- documents authenticated by a member of a regulated profession recording the distribution of shares and share movements (registers of registered shares or share movements), as well as any evidence of financial movements linked to share sales, acquisitions, capital increases or reductions;
- any other official document issued by the foreign authorities specifying the identity and address of shareholders, partners or unitholders, and the number of shares or rights held.
15.The French State disputes the place of residence of my holding company
In principle, tax treaties provide that for legal entities, the relevant criterion for defining their tax residence is the place of effective management.
On the French side, the Conseil d'Etat had already, in its decision on Compagnie internationale des wagons-lits, specified that "the place of management means the place where the persons exercising the most senior functions take the strategic decisions that determine the conduct of the business of that enterprise as a whole" (Conseil d'Etat, 10th - 9th SSR, 07/03/2016, 371435)
A recent decision, which redefines the criteria used to characterise a holding company's seat of effective management in France when its head office is located abroad, confirmed that foreign holding companies (in this case, the head office of a company was based in Luxembourg) should be considered as French tax residents if it was established - following L16 B searches and in particular by studying financial and tax management documents - that the main strategic decisions were taken from France by two co-founders, both of whom were domiciled in France, from the Paris head offices of other French companies in the group; the fact that the general meetings and the meetings of the board of directors were held in the state of the registered office (in Luxembourg) was not sufficient to establish the effectiveness of the place of the management headquarters, said holding company having meagre human and material resources in Luxembourg (an office of 13 m2 rented to a company domiciliation company, a single accounting employee present 10 hours a week, also employed by the domiciliation company, periodic statements of the bank accounts held by the company carried out by Luxembourg banks sent to a Parisian accounting firm). This decision illustrates the rigour with which the courts examine the clusters of evidence used to establish the place of effective management of a holding company.
The debate with the French State is essentially a question of fact, but it may be noted from this case law that although the place where the boards of directors of a company are located may constitute a clue to the identification of a place of management, this element alone is not sufficient, when compared with the other elements of the case, to determine it, and that the registered office is not de jure the place of effective management.
Any withholding taxes levied by the local authorities cannot give rise to a tax credit in France under the bilateral tax treaty between the two states in question. However, under French domestic law, it is possible to deduct the tax paid in the other state on dividend distributions, as Article 122 of the CGI provides that a dividend taxed in France is a dividend net of this foreign tax.
Our dedicated team of tax lawyers, fluent in French, English and Spanish, assists foreign companies on a day-to-day basis with their tax audits and disputes in France.
We are at your service to assist and advise you.
First contact
Nouvion Avocats offer a first consultation with one of our tax lawyers. The consultation will be either a face-to-face meeting, a telephone conference or by email.
The Benefits
The purpose of this consultation is to enable you to set out the background to your tax audit / tax litigation issues to help you decide whether to instruct one of our specialist lawyers to assist you.
During the consultation, we will establish whether your issue is something that the firm can assist with and if possible our initial observations and/or what the initial costs will be for us to deal with the matter.
Contact us by phone or email detailing your issue (e.g. information demand from the French administration, tax search, corporate and personal tax audit, tax litigation) attaching relevant information:
Our team
François NOUVION
Partner
Avocat at the Paris Bar
Magistère–DJCE de Droit des affaires et fiscalité, University Panthéon-Assas, Paris
Member of the Institut des Avocats Conseils Fiscaux (IACF), lecturer in taxation at the Sorbonne University and author of numerous articles on international taxation.
François is fluent in French, English and Spanish and works equally well in the three languages.
What his clients
say about him
Lyes Kaci
Avocat at the Paris Bar
Master 2 of the University Paris Sorbonne in Tax Law and Business Law, wrote his research paper on "The modernisation of tax administration and business", in connection with the dematerialisation of exchanges and procedures in the field of taxation.
Lyès is fluent in French and English and works equally well in both languages.
Iris de Soras
Avocat at the Paris Bar
She is a graduate from Skema Business School and holds Master’s degree in Business Law.
With ten years of professional experience, she has developed expertise in both and corporate taxation matters.
Iris is fluent in French and English and works equally well in both languages.
