Communications from the firm

in translation

A French company that was a subsidiary of a foreign company was inactive, but a bank account opened in its name had been used to help one of its foreign sister companies, which the tax authorities qualified as a gift subject to the withholding tax under Article 119 bis of

The tax authorities were considering taxing a Swiss resident who held a large property in France through intermediary companies, one of which was French. Frenkel & Associés argued that, although it could not be disputed that the French company had a preponderance of real estate assets, the Swiss resident escaped

In the context of a reassesment procedure concerning registration duties on the transfer of company shares, the tax authorities had served the procedural documents on the transferee company but not on the transferor (whose registered office was in Hong Kong). Frenkel & Associés, relying on the case law of the

In April 2023, Marc Pelletier will be co-chairing a conference organised by the IACF's Control and Litigation Committee on the abuse of rights. At this essentially practice-oriented event, Marc Pelletier will discuss a largely unknown subject: abuse of rights in the case law of the Court of Justice of the

In an important case which Frenkel & Associés is about to refer to the Administrative Court of Bordeaux, an alleged liberality granted by a French company, subsidiary of a Chinese group, to a Hong Kong sister company is at stake, which the administration claims to subject to the withholding tax

Frenkel & Associés has raised an unprecedented issue concerning the territorial jurisdiction of the tax auditors of the departmental public finance services as defined in article 4 of the amended decree of 16 June 2009. These provisions allow for territorial jurisdiction to be extended in certain situations "when justified by

In November 2022, the guide Décideurs – Stratégies financières et fiscales distinguishes Alain Frenkel as a "must" in the Wealth taxation category - regularization and litigation.

A senior manager of a large group was dismissed on spurious grounds, even though he had always received excellent evaluations from his superiors and colleagues. In the context of negotiations with his employer, he was awarded a settlement of almost one million euros. On the advice of the firm, he

Marc Pelletier has been a partner of the firm since 2013 and will join Racine Avocats, one of France's leading business law firms, on 1 June 2022 to develop its tax litigation practice. Alain Frenkel and Marc Pelletier will continue to work together, to the best of their respective abilities,