by Philippe STEBLER
The tax issues involved in a group’s governance structure are varied: the form of executive compensation, exemption from the IFI (wealth tax) and the Dutreil pact, which are delicately balanced, and which these developments aim to summarize.
The presence of several co-founders, the arrival of key managers, a changing family context, or even days that are too short for a single person are all reasons to expand a group’s functional and legal organizational chart.
Well-structured governance requires the effective coordination of at least three major tax issues for executives and their groups, the uncertainties of which have been highlighted by recent case law and legislative developments: income structuring, management of commercial real estate with regard to the IFI, and transfer of ownership.