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COFFRA GROUP’s – TAX SERVICES DISCLOSURE

Summary of Company

Coffra group SAS (French simplified stocks company) located in France, is an advisory firm that provides audit, accounting, legal, taxation, M&A and business support services. Coffra group’s tax department, which contributes approximately for 15% to its annual revenue, provides expert tax compliance services, tax litigation assistance and tax advisory mainly for legal entities.

In terms of our fees, Coffra group determines its rates in accordance with the ethical rules applicable to French chartered accountants, accounting experts and attorneys. Rates can be flat-rate for the simplest tasks), or based on an hourly rate; they depend on the complexity of the practice and have generally no relation to the possible tax savings. In the case of claims for tax refunds validated by the tax authorities, the fees may be based partly on the amount of tax refunded.

Its clients include but are not limited to SMEs and large enterprises based in France and abroad, nonprofit organizations but also individuals and high net worth individuals.

Coffra group’s Policies and Practices

Coffra group has a philosophy statement for the tax advice that they provide to their clients and their own engagement with governments and tax regulators, which is endorsed by all its employees providing tax related services. The philosophy statement reads as follows:

“As part of Coffra group’s commitment and in recognition of the role that taxes play in contributing to a healthy society, we use our professional judgment to provide advice regarding tax positions with multiple potential interpretations that accurately reflects the income and operations of the client in each jurisdiction for which the client seeks our advice based on the details of the client’s income and operations provided to us, and do not advise clients to take a position unless we believe it has at least a reasonable basis for being sustained by applicable tax authorities. If a client takes a tax position despite our advice to the contrary, we reserve the right to stop work for and terminate such client. In accordance with this tax philosophy, we engage with government and tax authorities on a collaborative basis and limit our advocacy activities with such authorities to (a) work for specific clients in need of regulatory compliance assistance and (b) providing limited financial support to the OEC (Ordre des Experts-Comptables) which advocates for the interests of the accounting industry as a whole (which may sometimes include limited tax advocacy). We maintain compliance with this policy through regular training of our employees and partners, internal policies on conduct, engagement documentation with our clients, and client retention reviews.”

Coffra group prohibits any employee from engaging in unlawful activities and in accordance with the chartered accountants’ and attorneys’ professional standards and regulations, at both national and international level, has a duty to withdraw from an engagement if they detect that their client is engaged in an unlawful or fraudulent activity. Additionally, according to anti-money laundering regulations enforced in France, Coffra group has a duty to report to the authorities any unlawful activity by its clients that involves money laundering, financing of terrorism or illegal arms trade, tax dodging and/or other criminal offenses. Our duty to perform a thorough anti-money laundering review is outlined in our client engagement process.

Coffra group, being a partnership of chartered accountants and attorneys, must comply with the ethical standards set by the OEC (Ordre des Experts-Comptables), the CNB (Conseil National des Barreaux) and H2A (Haute Autorité de l’Audit, formerly H3C).

Coffra group has a conflict-of-interest policy to check for conflicts of interest and independence related to client relations.

Furthermore, Coffra group has its own Ethical Code of Conduct, included in the employee digital handbook, which applies to all persons working within Coffra group, including Partners, employees, independent contractors or any agents engaged by Coffra group. The Ethical Code of Conduct is intended to promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; compliance with applicable laws and governmental rules and regulations; prompt internal reporting of violations of the Code; and accountability for adherence to the Code.

Coffra group provides fiscal and tax consultancy according to the principles of its Ethical Code of Conduct and according to the deontological principles approved by the OEC, CNB and H2A. They guide clients to adopt conducts inspired by the principles of loyalty to the state and observance of the law.

The firm has an Ethics and Compliance hotline, as an avenue for Coffra group personnel to anonymously report conduct that may be unethical, illegal, in violation of professional standards, or otherwise inconsistent with their Professional Code of Conduct.

Coffra group also declares they do not operate in low tax jurisdictions. Coffra group does not provide advice to clients who want to move to low tax jurisdictions with the aim of reducing or evading tax. Coffra group does not advice tax strategies whose aim is to reduce the global effective rate of an international group by any mean. Coffra group do not have a position on tax reform nor lobby in any way for tax reform or developing tax legislation. They do not take any public advocacy position on taxation issues.