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Denton Wilde Sapte (DWS) will convert to limited-liability partnership (LLP) status on Wednesday (1 November).
The LLP will apply to the UK offices only, but the LLP will own the network of 10 overseas offices.
The firm's foreign offices operate independently under the DWS banner, with overseas partners given voting rights for firmwide decisions. All partners' remuneration, on mixed lockstep, is based on the same amount of monetary value per point across the network.
Whereas an LLP is not charged corporation tax on profit in this country, the same is not true in other jurisdictions, including France.
DWS chief executive Howard Morris told The Lawyer that the firm expected to include Paris if French revenue laws were amended. Under the current regime French members of a UK LLP could be taxed twice.
Morris denied LLP conversion was a step towards becoming a limited company free to receive outside investment or even float.
He said: "We're as much in the dark as what will happen post-Clementi as anyone else.
"The reason we're converting is clients appreciate it's a sensible step to manage risk. I believe our risks are minimal."
The firm brought in PricewaterhouseCoopers as early as December 2005 to consult on the process. Retired corporate partner Simon Brown oversaw the conversion.