Single Equipe
Partager sur Linkedin

Grégoire
Loustalet

Partner

Grégoire 
Loustalet

Operational consultation is available, but there is no obligation to use it. It can be offset against a future assignment.

La peur du fisc bloque plus de projets que le manque d’idées

You have built something that works. Now you want to raise capital, recruit staff, expand into foreign markets and eventually sell the business on favourable terms.

Scrutiny from the authorities is a question that arises with every decision.

I’ve been asked this question for over ten years. It comes at a high cost, not in terms of tax, but in terms of hesitation. Fundraising campaigns are put on hold, subsidiaries never open and remuneration schemes are left as they are, with the attitude that they will be sorted out later.

My job is to make it disappear. I don’t promise zero risk, because that doesn’t exist. Instead, I put together robust cases to ensure that risk becomes a controlled factor rather than a constant source of anxiety.

Ce que je fais concrètement

Fast-growing tech companies are start-ups and scale-ups that are raising capital, expanding internationally and developing their R&D and shareholder bases.

– Directors, founders and established groups — remuneration decisions, holding companies, succession, disposals, transfer pricing.

The promise is the same in both cases: a clear, well-documented and defensible tax strategy, covering everything from advice to operational implementation.

The three stages of my presentation

1. Secure a strategic memo setting out the options, their respective advantages and disadvantages, and the recommended course of action. It is written in a way that can be understood by a senior executive, not just a tax specialist. This will enable you to make an informed decision.

2. Organise the setup, articles of association, contracts and drafting of legal documents, as well as the selection and coordination of service providers. A strategy is only worthwhile if it is implemented properly and documented as it progresses, rather than being pieced together under pressure three years later.

3. Defend
If the tax authorities contest the assessment, make sure you understand what they are seeking. Provide the relevant information and respond to the proposed adjustment and their comments. If necessary, take the case to court.

My method: no black box

There are three non-negotiable principles. They are also my clients’ principles.

No artificial tax arrangements There should be no shell companies, no bogus expatriation and no fictitious offshore invoicing. This isn’t just a matter of morals: a flimsy arrangement will come back to haunt you at the worst possible moment, such as during due diligence or in the middle of a funding round.

It is imperative that you grasp what we do, as it is essential to our success. If you don’t understand your own structure, you won’t be able to defend it and will become dependent on it. Let me explain. That’s also why I teach.

Structuring doesn’t mean slowing down, but rather making the most of the process. Une bonne architecture fiscale se conçoit à la vitesse de votre business. Le vrai coût du retard, ce n’est pas l’honoraire : c’est le mois perdu.

Why is technique important here?

I code. I have a good grasp of VBA and Python, which enables me to hold discussions with a product team at an engineer’s level and gain an in-depth understanding of digital business models.

This means tools that are tailor-made for my projects, which is really important.

– Tax calculation tools for all types of remuneration (salaries, dividends, BSPCE, management packages);

– Automation of crypto-asset reporting;

– Fundraising monitoring dashboards;

Analysis of data used to substantiate disputed services during a tax audit
When it is necessary to prove that an intra-group service actually took place, a spreadsheet is no longer sufficient.

My approach to transfer pricing is also driven by this: finding solutions that are rooted in the day-to-day reality of the business rather than theoretical policies that cannot be justified.

When should you contact me?

Situations that warrant an appeal ideally occur before the decision is made, not after.

Are you planning a fundraising round? Are you unsure whether your structure will pass due diligence?

You are setting up a subsidiary. Or you are relocating a team abroad. This could be R&D, sales or a holding company.

You are acquiring a company, selling one, or spinning off a business unit.

You are setting up a holding company for asset management or investment purposes, and you are doing this in a way that is both practical and effective.

You are moving to France or leaving the country.

You decide on your own executive remuneration and savings, and you are free to do this in whichever way you see fit.

Crypto-assets are held or received by you either for personal or professional use.

One of the following has been issued to you: a request for information, a request for correction or a notice of audit.

Regarding this final point, the sooner you call, the greater your flexibility will be.

Project → current status → sticking point → possible solutions.
Even if we don’t go on to work together, you’ll leave with practical advice.

Frequently Asked Questions

When should a start-up consult a tax lawyer?

The first key restructuring step is setting up a holding company, bringing in investors, implementing a BSPCE scheme and establishing an overseas entity. It is more expensive to correct a structure after the fact than to design it properly from the outset, and some corrections are no longer possible once the securities have been issued.

What should I do if I receive a notice of a statutory audit?

The authorities will inform you of the audit and the period it covers. You are entitled to be assisted by a legal adviser from the first meeting onwards. It is more important to prepare well for the hearing than to focus on the hearing itself. The key is to identify what the auditor is looking for, gather the relevant documentation, and ensure that you have control over what is disclosed, when, and in what form.

A tax lawyer – how does that differ from a chartered accountant?

The chartered accountant prepares and certifies financial statements, while the solicitor designs the legal and tax structure, drafts the necessary documents, safeguards the positions taken, and represents you in the event of a dispute with the tax authorities or before the tax tribunal. These two roles complement each other, and I regularly collaborate with my clients’ chartered accountants.

Do the authorities really monitor crypto-assets?

Yes, and increasingly so. The European framework (DAC8, the travel rule) governs the automatic exchange of information on crypto-asset holders. Voluntary compliance remains the least costly option, even before any request is made by the authorities. From 1 January 2027, crypto-asset exchanges will be required to report all their users’ data for 2026 automatically.

Once the authorities have access to all this data, numerous checks are expected. To avoid disastrous consequences, you can submit a regularisation application.

What happens on a first date?

60 minutes. We’ll review your project, your current situation, and any issues you’re facing, after which I’ll suggest some possible solutions. There’s no obligation, and you can deduct the cost from any future assignment.

Do you operate outside Paris?

The practice is located at 35 Avenue de Friedland in Paris (75008), and I work on cases throughout France, as well as internationally. Most of our communications take place via video conference.

Create, innovate, scale — and sleep soundly

Langues parlées : French | English

Education and Training
  • Doctorate in Tax Law – University of Toulouse 1 Capitole (2011) 
  • Master II in Fundamental Business Law – University of Toulouse 1 Capitole (2006)

 

Professional Experience
  • Since 2014 : Lawyer at the Paris Bar 
  • Lecturer, University of Paris I Panthéon Sorbonne
Associations and Networks
  • IACF (French Institute of Tax Advisers)
  • La Place Fintech/Défi
Audens Avocats
Privacy Overview

This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.