General skills
- Intra-group flows and reorganization advice (corporate conversions into ”agent/commissioner”, Toll Manufacturer, Low Risk Distribtors)
- Risk diagnostic on transfer pricing methods
- Tax audit assistance (pre-audit, strategy, negotiation)
- International tax dispute resolution (Ongoing Mutual Agreement Procedures – Double taxation treaties and European Arbitration Convention)
- Advanced Pricing Agreement (unilateral or multilateral rulings)
- Transfert pricing documentary strategy (optimization / centralization of documentation; benchmark; follow up in France and abroad of documentary supports / needs)
Specific skills
- Company’s valuation / Intangible assets valuation
- Permanent Establishment diagnostic – Branch registration – Function transfer
- Tax raid assistance