Denis-Emmanuel Philippe’s clients range from family holding companies to international corporate groups. He advises his clients on all issues they may face in connection with their companies (e.g., distribution of dividends to shareholders, transfer of the seat of the incoming or outgoing holding company, reduction of capital in kind or by way of loss compensation, liquidation of the company, sale of the company, reverse merger, partial division of real estate, etc.).


He also assists his clients during tax audits that can be particularly complex (taxation of a capital gain when the registered office is transferred abroad, application of the anti-abuse provision to a so-called “internal capital gain” arrangement, refusal to exempt a dividend with respect to the tax condition of article 203 (probably one of the most complex articles of the Income Tax Code).

In order to anticipate such tax audits, Denis-Emmanuel Philippe regularly submits ruling requests to the SDA on behalf of his clients, validating the tax neutrality of a transfer of the registered office, a merger or a demerger, the exemption of dividends paid by the subsidiary resident abroad or the non-application of Article 344 to a capital decrease based on motives other than the desire to avoid income taxes.