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.
26 July 2026
We are pleased to announce that Axtead has been ranked in the Chambers High Net Worth 2026 guide, in Private Wealth Law (France). A little over a year after the firm’s launch, this recognition rewards the groundwork laid in our very first months, when we submitted our candidacy to Chambers & Partners. We are especially […]
15 April 2026
In its April 2026 column, the Axtead team provides an overview of recent developments regarding the abuse of tax law and the prevention of tax fraud within the field of private client tax law. The column reviews several rulings concerning cash considerations (soulte) in contribution and capital reduction transactions. The Paris Administrative Court of Appeal […]
05 February 2026
We are pleased to announce the recognition of Arnaud Tailfer, founding partner of Axtead, by Chambers and Partners as Up and Coming. This distinction highlights a recognised expertise in tax litigation, both for corporates and private individuals. It reflects a practice built on anticipation, rigour and the pursuit of effective solutions. “Arnaud Tailfer won’t go […]
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 […]
15 January 2026
In its January 2026 column, the Axtead team provides an overview of recent developments regarding the abuse of tax law and the prevention of tax fraud within the field of private client tax law. The column highlights two opinions of the Abuse of Tax Law Committee (CADF) finding fictitiousness, on the one hand, in a […]
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.
