1. Areas of opportunity
In order to develop tax strategies which limit, if not eliminate, the cost of these timing differences, it is necessary to take into consideration the context in which the enterprise operates:
- the French tax context;
- the organisational and financial context;
- and, the international context.
2. Tax context of the group in France
As a first point, optimising the position of a tax profitable company or group of companies would not be achieved using the same methods as for a company or group with structural losses.
Similarly, the method of optimisation would also depend on whether the enterprise had opted for the tax grouping regime or not.
In this perspective, a loss making company should not opt to defer the taxation of gains if significant losses are at risk of expiring.
