EXPERTISE
Relations with the authorities, in France and internationally
Anticipate, defend, negotiate.
A dialogue that turns an imposed relationship into one you master.
Upstream
The most sensitive positions can be secured through advance rulings, advance pricing agreements on transfer pricing, and cooperative compliance programs.
During the audit
An active presence allows us to define strategy, select documents and arguments, steer discussions, and decide between settlement and litigation.
In litigation
We draft appeals, conduct the defense before the relevant courts, and manage mutual agreement procedures.
Recent or ongoing engagements
- Audits and litigation on global transfer pricing policies in France
- Transfer pricing audits, negotiations, and litigation in Korea, China, Italy, Spain, the Philippines and Thailand
- Tax and customs audits in Europe, Korea, China and the United States
- Mutual agreement procedures between France and Japan, and between France and Korea
- Support during voluntary police interviews and criminal proceedings
- Audits and litigation before social security collection authorities in France, Italy, Germany and the United Kingdom
Our signature
A fine-grained understanding of French and foreign tax authorities. France, Italy, the United Kingdom, the United States, China, Korea, Japan: we have advised on and led dozens of audits across these jurisdictions. Each administration has its own culture, calendar, and room for negotiation — and we read these from the field, working alongside local finance departments.
Proven experience on the most sensitive issues. Transfer pricing, criminal qualification, customs valuation: matters with high technical and reputational stakes are our home ground.