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Apprendre l x27 anglais juridique

Black Case LLP ?? Draft SETTLEMENT AGREEMENT BETWEEN THE UNDERSIGNED Laurent HOUTTAN Public Finance Administrator General Directorate of Public Finance on behalf of the French Tax Authorities hereinafter the ??Authorities ? On the one hand AND Pincemi Holidays France SAS having its registered o ?ce at allée de l ? Orme Rond Bailly Romainvilliers Paris registered with the companies' register of Meaux under number represented by its CEO Ms Maud ZARELLA duly empowered for the purposes hereof hereinafter the ??Pincemi France ? AND Pincemoi France SARL having its registered o ?ce at allée de l ? Orme Rond Bailly Romainvilliers Paris registered with the companies' register of Meaux under number represented by its CEO Mr Gérard MANVUSSA duly empowered for the purposes hereof hereinafter the ??Pincemoi France ? hereinafter together the ??Companies ? On the other hand hereinafter together the ??Parties ? CWHEREAS The Authorities carried out an accounting audit of the Companies from January to November in respect of Pincemi France and from February to November in respect of Pincemoi France for the period from January to December Further to these audits the Authorities issued two reassessment proposals intended for each Company on December By letters of February the Companies expressed to the Authorities their disagreement with the proposed reassessments The Companies then ?led an appeal with a higher administrative authority in the context of which they were able to meet Senior Tax Inspector Sarah FRECHI on May Further to these meetings the authorities indicated on May that they intended to maintain the reassessments in full During the audit procedures the discussions between the Authorities and the Companies brought to light a discrepancy in the interpretation of the economic condition and business of the Companies The Companies restate below their position since the beginning of the audits which is consistent with the business plan drawn up upon their creation as implemented since then Both Companies have been created for the purposes of operating a vacation resort referred to as Village aux Ours comprising a group of properties located in Bailly- Romainvilliers and operated under the Hilton trademark The occupants of such properties are persons who have acquired directly from Pincemi France or from other companies of the group to which the Companies belong i e the Hilton Vacation Worldwide group hereinafter ??HVW ? which has locations worldwide weeks of occupancy in the apartments of the property hereinafter the Timeshare Weeks The business plan of this resort relies on a long-term occupancy of the properties over the total projected term of the investment i e years The operation of this business has been allocated among the two Companies as follows Pincemoi France owns the buildings and leases them under long-term lease agreements to Pincemi France which is responsible for their operation In consideration of the -year term of the project the latter is in respect of the ?nancial years that were subject to tax audit as well as in respect of the following ?nancial years until the ?nancial year during