Tax

Transfer pricing has become an ever more prevalent topic due to the digitalization of the economy, the tax authorities’ heightened scrutiny in this area, and the extent and complexity of international projects aimed at reshaping group taxation. 

Fidal’s transfer pricing team is composed of twenty-two economists and/or lawyers ready to assist you in the following areas: 

• Analyze the risks inherent in transfer pricing policies; 
• Define, document and present the chosen policies to the administration, while taking account of any regulatory changes and VAT or customs impacts; 
• Valuate intangible assets, shares or activities in the context of intragroup transactions; 
• Educate your teams on these issues through ad hoc training; 
• Assist you in dealing with tax audits and resolving disputes, and representing you in tax controversies; 
• Negotiate advance pricing agreements (APAs).

With more than 30 lawyers specialized in VAT and indirect taxes throughout France, we serve a broad array of clients, both private and public, French and foreign. 

Our team can draw on a network of international specialists and provide scalable assistance adapted to your technological challenges (configuring the settings of information systems, reliable audit trails, e-invoicing). 

Through our contacts with the European authorities and our involvement in professional associations, we advocate for a simpler, more visible regulatory landscape. We defend our clients in tax audits and at all phases of tax controversies.

The focal point of numerous tax incentives, innovation is a key competitive factor for startups and multinationals alike. To support your innovation, Fidal’s specialized lawyers work in perfect harmony with high-level engineers and scientists dedicated to capturing the value of R&D and offering you a unique and comprehensive service in this field. 

Whether to manage and secure the tax treatment of your R&D activities (Research Tax Credit – RTC, Innovation Tax Credit – ITC, or other resource mobilization schemes), represent you in tax audits or structure your innovation investments, we deliver sound, innovative solutions and customized services adapted to your R&D objectives.

In a constantly changing international context, managing international flows is a key competitive challenge for businesses. The increasing tax burden on resources such as diesel, natural gas and electricity is spurring companies to adopt proactive strategies, aimed at qualifying for lower tax rates and exemptions, to stay competitive. 

The complex sectoral nature of customs law – featuring indirect contributions, the general tax on polluting activities (TGAP), dock dues and export controls – demands constant attention and monitoring. Our customs lawyers help you navigate this ever-changing landscape, from structuring your day-to-day customs operations to preparing for inspections and representing you in court proceedings. Backed by an international network, we offer a legal and operational approach to anticipating customs risks while identifying opportunities for optimization.

In the face of dematerialized tax audits and increasing electronic reporting obligations, our tax lawyers offer the best blend of tax skills and IT tools to assist your business in its digital transformation. 

From analyzing your FECs (files of accounting entries) during a tax compliance review, ensuring the conformity of your electronic archiving, electronic invoicing and POS software, to conducting mock audits and migrating your ERP data, our tax technology lawyers have the IT skills required to provide you with practical, effective solutions. 

Fidal’s offering enables companies to deal with both the tax and IT issues they may face in the event of a tax audit, from ensuring compliance to carrying out IT processing operations that lay the groundwork for optimized internal control.

Local direct taxes represent a recurrent yet growing share of business expenses. To deal with the weight, variety and complexity of local taxes, our team of experts provides audit, advisory and litigation support in the areas of territorial economic contribution, property tax, and the taxes on retail floor space, office space, commercial premises and warehouses in Ile-de-France. 

For day-to-day issues or one-off restructuring operations, from determining rental values to calculating added value, our proactive approach helps you best deal with the tax consequences of your transactions.