MANIFESTO

When it comes to innovation, taxation is often considered only in terms of the tax incentives. These tax incentives are implemented by governements to promote research and development and are a source of competition between them.

For a long time, France has introduced measures in favor of innovation, whether through the allocation of tax credits in favor of research and innovation, through favorable tax regimes intellectual property proceeds, through the benefits granted to investment through mutual funds for innovation, or through the creation of a tax and social exemption status for young innovative companies.

However, interactions between taxation and innovation are too often restricted to these incentive systems, but are in fact multi-faceted and complex.

Asymmetric cryptography and distributed networks have given rise to blockchain technology and crypto-assets and have profoundly changed the way economic actors interact with each other, thanks to consensus mechanisms achieving trust without a third-party.

These technologies have led to the emergence of a new class of assets (cryptocurrencies, tokens, etc.) which creates new uses and questions existing legal and tax qualifications.

New ways of representing value lead to new forms of investment such as :

• Digital representation of works of art in the form of non-fungible tokens (NFT);
• Tokens representing real estate or revenue rights, changing the way real estate transactions are made.

The same goes for artificial intelligence, which is disrupting data processing and opening up new uses for financial and tax data processing, not only by authorities during tax audits, but also for taxpayers, who can use it as a tool to identify risks and opportunities and as a powerful management tool for handling complex flows.

However, innovation should not be limited to research and scientific progress.

Innovative economic models have emerged in recent years redefining relationships between actors. The advent of digital platforms and the intermediation of companies in the flow of goods and services, both national and international, for companies and consumers, are prompting governments to redefine new rules for capturing value. Companies are faced with increased obligations and responsibilities in the implementation of complex territorial rules designed to cover the most innovative practices in the economy.

Beyond this component, innovation has social and organizational implications that question the concepts of tax law as much as disruptive technologies and models.

For many years, tax law has been striving to go beyond the physical criteria of territorial attachment of taxable bases to encompass digital activities, but new organizational methods are facilitating internationalization and increasing flow complexity.

The development of remote working, the relocation of managers and self-employed workers, and new decentralized forms of governance are reducing the influence of territorial borders and raising new questions about the status of permanent establishment and the geographical scope of business projects.

In addition to these major issues, there are other issues related to States’ public policies. The tax lever can be an incentive or a sanction to respond to environmental challenges, to face competition from other countries, or to respond to an uncertain economic and geopolitical context.

However, the complexity of tax standards can be an obstacle to their development.

To face these challenges, we have drawn inspiration from the values we share with innovation players: ANTICIPATION and ADAPTATION.

To take part in your company’s success, we get involved as early as possible by working with you to imagine tomorrow’s events. Anticipating and understanding future events, developments in your activity and changes in tax rules allow us to provide secure, relevant and sustainable advice.

The challenges of innovation also require pragmatic and operational advice.

Adapting is the way we take ownership of your issues to provide you with optimal responses. Because we understand your history, your business and because we support you in the field, we offer tailor-made solutions that are consistent with your business model, your organization and your values.

To assist you in your most innovative projects and because we share these common values, we embark with you on an experimental path and reinvent our consulting services with you.