Abuse of tax law: publication of the firm’s quarterly column in “Ingénierie Patrimoniale” (JFA Editions)
10 September 2025
In the July 2025 column, the Axtead team reviews recent developments regarding the abuse of tax law and the prevention of tax fraud.
Notably, the column analyzes several consistent rulings penalizing contributions involving cash considerations (soulte), which were deemed an abuse of law due to a lack of genuine economic justification. It also examines a May 28, 2025, ruling from the Paris Administrative Court of Appeal (CAA) that upheld the validity of split-interest ownership (démembrement) of SCI shares for the benefit of a wealth holding company, providing a useful framework for identifying artificial arrangements.
The team also comments on a February 12, 2025, Cour de Cassation ruling regarding the proportionality of the 80% penalties applied in cases of abuse of law, as well as a March 12, 2025, decision affirming the authority of final criminal judgments in tax matters (res judicata), even when an acquittal was granted on the basis of the benefit of the doubt.
Finally, the column discusses the publication of a new fact sheet by the tax authorities in the “Map of Abusive Practices and Arrangements,” focusing on foreign employee share ownership plans operated through unreported accounts.
This contribution reflects Axtead’s commitment to playing an active role in shaping legal doctrine and contributing to the contemporary tax debate.
29 January 2026
Axtead has been awarded a Special Mention by the jury of the 2026 Sommet du Droit, in the category Wealth Taxation – Regularisation and Litigation. This distinction recognises the emergence of Axtead, a young firm led by a team of experienced lawyers, as well as the clear and demanding vision guiding its development. This recognition […]
29 December 2025
We wish you a serene year ahead, filled with happiness, new projects, and success, within an increasingly demanding tax and wealth-planning environment.
02 November 2025
In its October 2025 column, the Axtead team provides an in-depth overview of recent developments regarding the abuse of tax law and the prevention of tax fraud within the field of private client tax law.
23 September 2025
On November 6, 2025, Axtead celebrates its inauguration at the Musée National Jean-Jacques Henner. Within this timeless setting—a nineteenth-century hôtel particulier—we invite you to an encounter between painting, contemporary creation, and music.
10 September 2025
In the July 2025 column, the Axtead team reviews recent developments regarding the abuse of tax law and the prevention of tax fraud.
28 August 2025
Arnaud Tailfer and Arnault Devis were invited by Le Figaro Magazine to share their expertise on the tax challenges surrounding expatriation and international wealth transmission.
