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Dispute Resolution

The sharpest argument is the one that leaves nothing left to say.

Tax litigation begins with silence. A judge, a file, and the quiet authority of written advocacy. What matters then is not how much you say, but how clearly you articulate your thoughts. Facts must unfold, not be narrated. The goal is to render the opposing case untenable through strategic framing and substantiation.

To dispute well is to do more than answer. It is to rebuild the ground on which the answer stands. Our arguments are valued for their precision and internal coherence. They settle into a structure chiseled with intent, a path laid for thought to follow. Each submission is conceived as a line of reasoning: not a sequence of sections, but a continuous progression — from context to confrontation, from law to conclusion.

Our approach aims to preserve structure, reputation, and alignment with long-term strategy.

Illustrative Expertise

Corporate Taxation

  • €800,000 corporate tax refund secured before the Cour administrative d'appel de Paris
  • Successful CFE appeal for a leading agri-food group → ruling cited as precedent on territorial tax liability (prior to LS2P)

Strategic Litigation

  • Global settlement negotiations with Bercy (Ministry of Finance) on matters exceeding €100M in tax exposure (prior to LS2P)
  • Ongoing matters handled by LS2P Avocats, including cases involving international tax issues

Tax Jurisdictions

  • Representation before multiple Administrative Courts and Courts of Appeal across France (prior to and within LS2P)
  • R&D tax credit claim exceeding €500,000 → structured administrative challenge followed by litigation proceedings
50+ TAX DISPUTES HANDLED

Extensive track record of resolving cases pre-litigation through strategic negotiation. Cumulative experience, before and since the foundation of LS2P Avocats.

Where you stand often depends on how you start.

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