STCPARTNERS has developed an expertise in the tax structuring of mergers and acquisitions, in tax litigation, in transfer pricing and more generally, in all direct and indirect corporate tax matters in both a domestic and an international context. Our corporate tax practice advises corporates, investment funds and individuals from all jurisdictions in connection with transactions such as acquisitions, LBOs, asset finance and disposals in all classes of assets, including properties.
Our corporate tax practice has particular expertise in the following:
Mergers & acquisitions structuring
STCPARTNERS applies its expertise to offering adequate and tax efficient structures for acquisitions and financings regardless of their context (including notably, general corporate acquisitions, LBO transactions, LMBO transactions, etc.) and at both domestic and global levels.
Using proven due diligence methodology, STCPARTNERS also assists vendors and buyers in identifying tax issues at target(s) level.
Tax management strategies
STCPARTNERS daily assists clients with their corporate tax management strategies regarding both direct (i.e., tax result assessment, effective tax rate management, etc.) and indirect (i.e., VAT) taxes. Beyond daily tax management, STCPARTNERS also assists its clients with respect to exceptional reorganizations (such as mergers, partial asset contributions, demergers or else) by providing tailored and tax efficient solutions (e.g., tax deficit management, obtaining of tax rulings from the relevant tax authorities, intercompany transactions, etc.).
STCPARTNERS assists its clients during tax reviews and takes a pragmatic and constructive view in that respect. Indeed, priority is given to negotiated solutions as a result of a constant and sustained dialogue with the auditors and the relevant administrations. Such view is underpinned by our strong insight of the judicial and administrative practices. Nonetheless, STCPARTNERS also brought a number of cases before the judicial and administrative courts.
As a result, STCPARTNERS’ expertise in tax litigation allows it to anticipate future tax litigation when advising its clients.
Cross-border tax issues – Transfer prices
STCPARTNERS has set up a dedicated team of experts in relation to transfer prices. Indeed, the practice focuses on assisting clients with the definition of transfer price systems (be they administrative services or operational flows) and the re-invoicing of intangibles used. Our practice also provides existing policies analysis and assistance with the drafting of the transfer price documentation.
Our team of experts handles litigation of any kind whatsoever at both domestic and European levels and provides support with the negotiation of prior transfer price agreements.
Real estate tax
STCPARTNERS’ expertise in real estate tax focuses on offering tailored and innovative solutions in connection with the acquisition of real estate portfolio and real estate outsourcing. In particular, STCPARTNERS assists its clients in choosing acquisition and finance structures which are adapted to their needs (e.g., setting up of real estate investment schemes (OPCIs), ability to opt for the SIIC tax regime) and thereafter, provides support at implementation stage.