Intra-group Operations: Tax Optimization Strategies

Public

• Administrative and financial directors
• Directors and tax managers
• Tax experts
• Accounting directors, accountants
• Management controllers
• Chartered accountants and auditors
• Lawyers and jurists

Prerequisites:

No prerequisites

Programme

Satisfaction rating 2025: 10/10

GOALS

• Master the tax treatment of intra-group operations, integrated or not
• Secure operations to optimize the group’s overall tax burden
• Examine the consequences of the latest jurisprudential solutions

OPERATIONAL BENEFITS

• Identify intra-group exchanges enabling optimization
• Measuring the risks of intra-group exchanges
• Secure and document your tax decisions based on case law solutions

EDUCATIONAL PROCESS

I/ Identify risks in intra-group transactions

• Master the market price imperative and its exceptions Define and identify indirect subsidies (inside or outside tax integration)
• Determine the price of current transactions (goods, services)
• Symmetrical corrections in the event of recovery of a group company? Feedback: difficulties encountered in practice

II/ Mastering the abnormal management act

• Definition and outlines of the theory Freedom of business management?
• The different application cases: Documenting your operations and tax decisions

III/ Secure the management fees policy

• What must, what can be invoiced How to calculate and justify them Articulation with other invoicing
• Manage the special cases of common managers

IV/ Manage the legislative framework for financial costs

• Secure the remuneration of loans and cash advances
• Devices limiting the deductibility of financial charges
• The new net financial charges regime
• Cash centralization

V/ Appreciate the impact of tax flows in tax integration

• Appreciate the need to establish an integration agreement
• Distribution of tax in groups: types of integration agreements Distribution of costs / tax savings
• Compensation for the loss-making subsidiary
• Risks in the event of a group outing

VI/ Monitor fixed asset transactions

• Identifying a disguised transfer of assets
• The consequences of a sale/purchase at an increased or reduced price
• The particular case of transfers and acquisitions of securities

VII/ Measuring the fiscal constraints of bailout operations

• The use of debt waivers and subsidies
• The effects of a return to better fortune clause
• Direct and indirect aid within or outside tax integration

Evaluations

Teaching methods:

• The trainer alternates the presentation of the legal rules necessary to master each operation with practical cases or numerical exercises essential to concretize the participants’ understanding.
• Specific cases drawn from professional experience will be analyzed and recent case law will be developed to enable risk-taking to be measured and, where appropriate, to construct an argument to support tax decisions.

Evaluation methods:

• A multiple choice question is offered at the start of the training and then at the end of the course in order to measure the contribution of the training.
• At the end of the training, the learner immediately evaluates the quality of the training.
• After the training, the participant evaluates the impact of the training.