Corporate tax policy: securing a strategic decision before its implementation

Some transactions are too important a tax issue to rely on a simple theoretical assessment.

Significant investment, restructuring, favourable tax arrangements, intra-group transactions or atypical schemes may justify seeking a prior position of the tax administration in certain situations.

The rescript then becomes a Decision-making instrument It allows a more precise assessment of the level of security attached to a strategy before committing capital or implementing a structuring operation.

Know when to look for an administration position

Rescription is not always appropriate.

An insufficiently prepared demand can unnecessarily freeze a position, while a legally sound situation can sometimes be secured by in-depth analysis without the need for prior action.

The value of counsel therefore lies first in the diagnosis: measuring the level of uncertainty, assessing the doctrine and jurisprudence available, identifying the economic consequences of an unfavourable position and determining whether recourse to rescript is really the best option.

Secure without giving up tax performance

The search for security must not lead to abandoning any ambition of optimisation.

The firm analyses the various possible scenarios in order to identify those that offer the best balance between tax advantage, legal strength and corporate visibility.

In particular, this expertise allows us to rethink an operation when a scheme appears too exposed, or on the contrary to reinforce a strategy when its legal basis is sufficiently robust.

Master Edouard Pruvost specializes in consulting on corporate tax strategy and analysing complex tax issues. The firm intervenes upstream of decisions with high stakes in order to assess their level of security, compare alternatives and identify the most efficient fiscal solutions. To have your project analysed and to benefit from tax strategy advice, contact the firm.