Arsene Taxand - M&A Private Equity

Acquisition tax audit/Preparatory tax audit

• Detailed examination of the fiscal aspects of the acquisition (analysis of the information memorandum or vendor due diligence, in-depth review in a data room) and coordination with the legal or financial teams
• Organisation of the tax review in preparation for internal restructuring/assistance operations in the implementation of vendor due diligence
• Coordination of international tax audits with the Taxand network

Tax advice to optimise the groups’ domestic or multinational growth and internal restructuring operations:

• Support in determining tax strategies/tax planning
• Domestic or cross-border acquisition tax structuring, tax optimisation of domestic or international joint venture structures
• Tax optimisation of financing and of recapitalisation needs, tax monitoring of cash pooling transactions
• Tax management and optimisation of pre- and/or post-restructuring international flows (dividends and interest)
• Tax management of restructuring operations, notably mergers, de-mergers, partial contribution of assets… and reorganisation of the group (transfers of intangible assets, circulation of intra-group receivables, etc.)
• Follow-up and assistance in any discussion with the tax authorities
• Follow-up and assistance in implementing the operations.

Tax assistance for investment funds in structuring acquisition transactions

• Determination of acquisition structures
• Assistance in the tax structuring of the financing of operations (analysis of the tax impacts of debt instruments, of shareholders’ equity or quasi-shareholders’ equity, securing and optimisation of the tax deductibility of the acquisition debt, etc.)
• Tax optimisation of the movement of cash and post-closing tax impacts (in particular with respect to VAT, intra-group services rendered, etc.)
• Tax modelling of the cash flows and business plan
• Follow-up with and assistance in the implementation of operations in close co-operation with the management and teams of the management company, assistance with the financial analysis of the transaction’s components (taxation of management, optimisation of the target’s tax situation).

Tax assistance with the fund’s internal structuring, based on the remuneration of the management company's teams

• Tax assistance in the structuring of the fund and the tax management of flows to French or foreign shareholders/unit holders
• Tax structuring of carried interest

• Thanks to the complementary areas of expertise in all aspects of taxation of our Arsene Taxand teams, we are able to meet all of our clients’ needs (indirect taxation, customs, and transfer pricing, local taxation, taxation of management company directors or teams).
• Our highly practical and financial approach to tax issues enables us to understand all of the components of tax structures in their entirety and to offer pragmatic solutions.
• Our ability to quickly mobilise experienced teams to carry out all necessary work, such as tax reviews.
• The synergies and resources within the Taxand network enable us to assist clients internationally, especially multinational groups.
• -Our network of partners and experts, in particular in M&A, labour law, corporate law, stock market law, but also with respect to financial issues, enables us to master all of the aspects related to the structures put in place.