Morgan Vail

Morgan Vail is a Partner in the Tax department, advising French and international clients on complex tax matters across transactions, advisory and disputes.

He is regularly involved where tax is both a constraint and a lever in strategic decisions: in transactions, contentious situations and business transformations.

He has extensive experience in tax controversy, representing clients in audits, dawn raids and high-stakes disputes with the French tax authorities. He leads negotiations and litigation with a clear focus on defending positions, managing exposure and securing outcomes, including through proactive claims and offensive tax strategies.

Morgan works at the intersection of tax and business strategy, supporting clients on acquisitions, disposals, joint ventures and reorganizations. He partners closely with other practices across the firm to design tax frameworks that hold under scrutiny and work in practice. He stays involved beyond signing, supporting implementation and day-to-day matters, including tax consolidation, intra-group flows (royalties, dividends, interest, management fees), some VAT issues, withholding tax and compliance.

He also advises on securing legal certainty through rulings and advance approvals, drawing on his experience engaging with tax authorities, policymakers and public institutions. This allows him to anticipate regulatory developments and help clients navigate an evolving international tax landscape, including BEPS-related initiatives.

Morgan’s practice spans a broad range of industries, including TMT and the digital economy, as well as energy, infrastructure, transportation, FMCG / retail and entertainment. He regularly advises on transfer pricing, business restructurings, permanent establishment exposure, beneficial ownership, value chain alignment, IP structuring and intra-group financing. He also has significant experience with digital services taxes, including the French DST, from a compliance, audit and advisory perspective.

Morgan’s approach is straightforward: tax advice is only as valuable as its ability to be implemented and sustained over time. He focuses on delivering clear, actionable positions and working alongside clients to carry them through; from structuring to execution, and where needed, to defense.

His combined experience across advisory, transactions and disputes enables him to provide a seamless, fully integrated approach to tax matters, both on standalone issues and as part of complex, cross-border mandates.