Family-Owned Businesses
Axtead supports family-owned businesses in managing their day-to-day tax operations, adapting to their specific operational realities.
We provide dual-level support:
- Ongoing guidance for internal functions (CFOs, Legal Departments, Executive Management);
- Strategic advisory for high-stakes exceptional transactions.
Our services include:
- Annual tax reviews & year-end procedures: validating accounting and tax treatments, managing exceptional income and expenses, and optimizing the tax burden at both the group and holding company levels;
- Outsourced tax support: managing compliance and reporting obligations, addressing day-to-day tax inquiries, providing regulatory monitoring, and supporting internal teams;
- Complex transactions: mergers, asset contributions, business transfers, group reorganizations, and registered office relocations—combining proactive tax impact analysis with legal securing and operational implementation;
- Tax authority relations: support during audits, voluntary disclosures, and requests for tax rulings (rescrits) to secure legal positions in sensitive contexts.
We work in close collaboration with the company’s existing advisors (accountants, auditors, and partner firms) within a philosophy of long-term partnership. Our priority: to empower executives to make informed decisions within a managed and sustainable tax framework.
Questions
Managing liquidity between companies in the same group can be structured through various legal and tax mechanisms:
- Cash pooling agreements, with centralized cash management or the offsetting of intra-group flows;
- Current account advances, provided they carry arm’s length interest rates and avoid any characterization as an abusive tax scheme;
- Dividend distributions, optimized through the French Parent-Subsidiary regime (régime mère-fille);
- Intra-group invoicing, managed through service agreements based on justifiable economic value and arm’s length principles;
- Mergers or restructuring operations, when a more structural rationalization of the group’s organization is required.
We assist you in implementing secure tools tailored to your specific operational needs.
The arrival of a new shareholder—whether through a share sale, capital increase, or contribution of assets—raises several critical tax issues that must be anticipated:
- Taxation for the seller: applying the standard tax regime (flat tax or progressive scale with applicable reliefs), provided the transaction qualifies for specific favorable tax treatments;
- Registration duties: share transfers are subject to proportional registration duties (stamp duties);
- Transaction structuring: choosing between a direct sale of shares or a capital-based operation;
- Compliance with existing agreements: the entry of an outside partner may jeopardize existing tax arrangements (particularly “Dutreil Pact”) or require updates to the Bylaws or Shareholder’ Agreement to preserve the family’s balance and control.
We assist our clients in securely structuring the entry of new partners, integrating the tax, legal, and wealth management dimensions unique to family-owned groups.
From a tax perspective, transferring a company’s registered office outside of France is generally treated as a cessation of business, unless a permanent establishment is maintained within the country. This triggers several immediate consequences:
- Immediate taxation of latent capital gains, particularly on fixed assets;
- Acceleration of tax on deferred profits, tax-exempt provisions, and net long-term capital gains;
- Specific reporting and disclosure obligations;
- Impact on withholding taxes, VAT, and accounting standards, depending on the regulations of the new host country.
We intervene proactively to identify potential tax risks and propose mitigation strategies. Furthermore, we guide our clients through the necessary formalities with French authorities to ensure a seamless and efficient cross-border transfer.
