Corporate tax litigation: anticipating risk through tax strategy

A tax dispute often originates well before the procedure itself: choice of structuring, qualification of a transaction, processing of a flow, insufficient documentation or divergent reading of a tax rule.

For the company, therefore, the issue is not to wait until the disagreement is formed to measure the tax exposure of a transaction.

Identifying fragility before it becomes a dispute

Some decisions have a higher tax risk than others: restructuring, intra-group transactions, divestitures, international flows, VAT or multi-entity arrangements.

A strategic analysis identifies the points that could be discussed, assesses the financial impact and assesses whether a different structuring would reduce risk exposure.

Preserving the economic value of the transaction

The prevention of litigation is not just about seeking maximum security. It also implies safeguarding the tax interest of the transaction.

The role of the board is then to find the right balance between optimisation, legal robustness and risk management, so that the company can continue its project with a clear vision of its tax consequences.

Master Édouard Pruvost specializes in consulting on corporate tax strategy. It assists managers in the analysis of transactions likely to present a significant tax risk, with the aim of optimizing the structure chosen while reducing exposure to a future dispute. To benefit from a strategic analysis of your tax situation, contact the firm.