Transaction Tax Services

Presentation of our expertise

Eight Advisory Avocats proposes a broad array of services in the field of transaction tax at European and international levels.
For international cross-border projects, we work in relation with our tax correspondents network, which allows us to cover more than 50 jurisdictions.

Our support

Our teams are able to provide you with any kind of tax assistance: due diligence, structuring, modeling, post-closing reorganizations and all the related tax analysis.

Buy side due diligence

Tax due diligence of the companies of the target group.
Quantification of tax risks, assessment of their likelihood and practical recommendations.
Review and negotiation of the tax clauses of the SPA.
Assistance for the Q&A with insurers.

Vendor due diligence

Vendor tax due diligence of sold companies.
“VDD” or “Fact Book” approach (quantification v. non-quantification of risks) depending on your needs.
Assistance for the Q&A with potential investors.

Independent tax review

Independent tax review of the group companies.
Quantification of tax risks, assessment of their likelihood and practical recommendations.

Tax structuring

Analysis regarding potential relevant acquisition structures depending on the particularities of the transaction.
Design of the debt allocation and cash repatriation strategies.
Preparation of tax structuring memorandums.

Tax modeling

Critical review from a tax perspective of financial models.
Preparation of tax opinions on financial models.

Tax modeling (Infrastructure)

Review of the tax treatment of accounting income.
Review of the tax treatment of expenses and in particular amortization.
Review of the tax rules limiting the deduction of financial expenses.
Review of the potential tax leakages related to cash flows.
Review of the use of tax assets (in particular of tax losses).

Post-closing reorganizations

Streamlining of intragroup flows and of the transfer pricing policy.
Streamlining of the legal structure (mergers, partial asset contributions, transfer of shares).
Setting-up of tax consolidated groups.
Tax ruling requests.

Our Team

Team

Guillaume Rembry

Managing Partner

Tax

Hubert Christophe

Partner

Tax

Kevin Peau

Partner

Tax