The situation

Founder of a SaaS company based in Sophia Antipolis, aged 45, who had just signed a sale agreement valuing his business at nearly €4 million. He held BSPCEs (founder warrants) acquired from inception, generating a highly significant capital gain. Without advance structuring, the tax applicable to the sale would have amounted to nearly €600,000 in immediate liability — a substantial erosion of the capital available for the future.

Our approach

• Implementation of a contribution-disposal scheme under Article 150-0 B ter, via the creation of a family holding company, enabling full deferral of tax on the entire capital gain
• Management of the mandatory reinvestment obligation: 60 % of net proceeds reinvested in eligible private equity funds and European SCPIs through the holding company
• Subscription to a Luxembourg life insurance contract in unit-linked form for the liquidity outside the holding, providing access to funds not distributed in France
• Opening of a maximised Plan d’Épargne Retraite (PER) to shelter residual self-employed income in the year of sale
• Anticipation of the earn-out clause over 18 months and specific structuring of its tax treatment

The situation

A Franco-British couple, aged 55, resident in Monaco for nearly twenty years. They were considering a return to France (Alpes-Maritimes) to be closer to their children. Their estate comprised several accounts abroad, real estate assets in the Principality, and a diversified financial portfolio. Their matrimonial regime, entered into under English law, was incompatible with French law. They were unaware of the tax consequences of an unprepared return: income tax, IFI wealth tax, social contributions on investment income, and the Monegasque exit tax.

Our approach

• Full pre-return tax audit: comparative simulation of three scenarii (immediate return, return in 12 months, return in 24 months) with quantification of income tax, IFI, and social contributions impacts
• Coordination with a notary and a tax lawyer for the regularisation of undeclared foreign accounts and the adaptation of the matrimonial regime to separation of assets
• Subscription to a Luxembourg life insurance contract prior to the change of residence, guaranteeing tax neutrality upon transfer of the financial portfolio
• Implementation of an anticipated gift distribution to the three children before the official return to France, taking advantage of intact allowances (€100,000 per child per parent)
• Structuring of a family SCI for the residual real estate, facilitating management and future transmission

The situation

A retired business owner, aged 68, resident on the French Riviera. His estate, valued at approximately €6 million, consisted primarily of real estate in Cannes and family SCI units, alongside a financial portfolio invested 100 % in euro-denominated funds. His annual IFI (wealth tax) bill stood at €28,000 and was rising each year in line with property revaluation. His succession was not organised: three children including one non-French-resident European, no adapted will, and potentially very high inheritance tax exposure.

Our approach

• Dismemberment of ownership on two properties: donation of bare ownership to the resident children, providing immediate reduction of the IFI base and crystallisation of the value transferred
• Drafting of a Dutreil Pact on the family SCI units, enabling a 75 % exemption on their value for inheritance tax calculation purposes
• Complementary gifts to each child within legal limits, further reducing the IFI base
• Full diversification of the financial portfolio: transition from 100 % euro funds to an allocation of 40 % dynamic unit-linked funds, 30 % European SCPIs, 30 % euro funds, targeting an additional annual return of +4.2 percentage points
• Drafting of a will with a renvoi clause adapted to the law of residence of the non-resident child, in application of EU Succession Regulation No 650/2012