Tax

French tax advice for innovative businesses, founders, executives and investors throughout their business development, wealth planning and international mobility.

d&a partners’ Tax practice advises businesses, founders, executives, shareholders and investors on the structuring and protection of their French tax position, with particular attention to situations in which corporate and personal tax issues need to be considered together.

Our practice covers corporate and holding structures, founders’ and executives’ taxation, disposals and reinvestment transactions, private wealth, international mobility and dealings with the French tax authorities.

The firm also has longstanding experience in the French taxation of crypto-assets and onchain business models, advising both private investors and businesses operating in the sector.

Taxation of businesses, founders and executives

The Tax practice advises businesses, founders and executives on the French tax structuring of their activities and on transactions arising throughout the development of the business.

We advise on operating and holding structures, financing and reorganisations, acquisitions and disposals, and the French tax consequences of strategic business decisions.

We also advise founders, executives and shareholders where their corporate and personal tax positions intersect, including compensation and distributions, ownership structures, holding companies, share contribution and reinvestment arrangements, business disposals and succession planning.

Where an activity or transaction gives rise to particular uncertainty under French tax law, we also assist clients in securing the proposed tax treatment, including through applications for formal tax rulings.

Crypto-assets and onchain business models

The taxation of crypto-assets has been a longstanding area of practice at d&a partners. We advise private investors and businesses on French tax issues arising from digital assets and onchain business models.

Our practice covers disposals of crypto-assets, mining, staking, airdrops, DeFi transactions, corporate ownership of crypto-assets, the structuring of income and transaction flows and applicable reporting obligations.

We also advise on VAT issues specific to the crypto sector where the treatment of services, token flows or the identification of the relevant customer requires a combined understanding of the legal, tax and technical structure of the model.

Where transactions have taken place across multiple exchanges, wallets or protocols, we can also assist in reconstructing and analysing historical records for French tax purposes.

Private wealth, succession and international mobility

The Tax practice advises private clients, investors, entrepreneurs and executives on the organisation and transfer of their wealth, taking into account personal assets, business interests and holding structures.

Our work includes holding companies, French real estate and property-owning companies (SCI), gifts and inheritance, and the transfer of businesses, shareholdings and crypto-assets, working where appropriate with notaries, family offices and other advisers.

We also advise clients relocating to or from France on French tax residence, tax treaties, exit tax, foreign income and assets, foreign structures and pre-departure or pre-arrival planning.

Where an executive’s relocation is accompanied by a transfer or reorganisation of business activities, we also address corporate tax residence, effective place of management and permanent establishment issues.

Tax regularisations, audits and disputes

The Tax practice represents clients in their dealings with the French tax authorities, both before an audit and throughout reassessment and litigation procedures.

We assist with tax regularisations, information requests, personal tax examinations, corporate tax audits, reassessments, administrative appeals, claims and proceedings before the competent courts.

The firm has particular experience in audits and disputes involving crypto-assets and transactions whose French tax treatment requires detailed legal and factual analysis.

We also assist with source-of-funds and tracing matters where the history of digital assets must be reconstructed and presented to the French tax authorities, banks, notaries or other professionals.