Prosecutors Seize 96 Percent of the Tax Loss France Estimates in the McKinsey Inquiry
France’s national financial prosecutor had 65.2 million euros seized by the Belgian judiciary in the tax investigation into McKinsey & Company, an amount equal to 96 percent of the tax loss as the French prosecutor estimates it. Pascal Prache, the national financial prosecutor, and Julien Moinil, the Brussels public prosecutor, announced the seizure in a joint statement on Friday 4 September; the 65.2 million figure is the one Reuters reported. The money was taken on 19 August. The seizure is protective, no court has ruled on the merits, and the preliminary investigation continues.
Prosecutors rarely secure almost the whole value of a claim while an investigation is still preliminary. What the measure shows is the scale of the case they believe they are holding, four years and four months into a file that has yet to produce a charge.
What the seizure is measured against
The inquiry runs on figures a French Senate commission of inquiry into the influence of private consultancies on public policy published in March 2022, still the only detailed public account of the firm’s French tax position. It found that McKinsey is liable for French corporate income tax and had paid none of it.
| McKinsey in France, as recorded in the 2022 report | Value |
|---|---|
| Turnover, 2020 | 329 million euros |
| Share from the public sector | About 5 percent |
| Employees | About 600 |
| Corporate income tax paid | Zero for at least 10 years |
French Senate report number 578 of the 2021 to 2022 session, deposited 16 March 2022. Turnover, headcount and the public sector share are the report’s own figures for 2020.
The report called the arrangement a caricatural example of tax optimisation. Its mechanism was transfer pricing. The French entities, permanent establishments in the tax sense, paid the Delaware parent for pooled costs covering general administration, use of the brand, assistance within the network and secondment of staff. Those payments are deductible, so they reduce taxable profit, and the report found them large enough to contribute to making the French taxable result nil or negative for at least ten years. That is a parliamentary finding about tax, not a criminal judgment, and the investigation grew out of it rather than being decided by it.
| Comparison, our calculation | Result |
|---|---|
| Seizure against the estimated tax loss | 96 percent |
| Seizure against 2020 French turnover | About 20 percent |
| Seizure against 2020 French public sector revenue | About 4 times |
Computed from the 65.2 million euro seizure and the 2020 figures above. The public sector line takes about 5 percent of 329 million euros, roughly 16.5 million. Separately, a seizure equal to 96 percent of the estimated loss implies a loss of about 67.9 million euros.
Every one of those ratios is struck against a 2020 base, which matters more than it looks. The firm’s French turnover in the years since has never been published, and the prosecutors have not said which tax years their estimate covers, so the ratios size the seizure against the last year anyone measured rather than against the years in dispute. Read them as a measure of scale and not as an effective tax rate.
The revenue figure works out at roughly 548,000 euros per employee in 2020 on our calculation, which is why a nil taxable result invited the question, though it does not by itself establish what profit those activities should have left in France. That is the question the investigation exists to answer. The same report recorded French state consultancy spending above 1 billion euros in 2021, made up of 893.9 million from ministries and 171.9 million from a sample of 44 operators. McKinsey’s own public sector revenue of roughly 16.5 million euros the year before is a small fraction of that, on two different years and so indicative only. The case has never been about the size of the contracts. It is about where the profit on them was booked.
Four years and four months from the opening to the seizure
The prosecutor opened a preliminary investigation on 31 March 2022, a fortnight after the report was deposited on 16 March, on a count of aggravated laundering of tax fraud. Witnesses and suspects were heard through 2025 and 2026, and it was after those hearings that France asked Belgium for help under international mutual legal assistance. The Belgian judiciary executed the seizure on 19 August 2026, four years and four months after the file was opened on our calculation, and it was announced 16 days later.
McKinsey called the protective seizure a procedural measure linked to a preliminary investigation conducted by the French authorities, and said it does not constitute a judicial decision. The firm said it continues to cooperate with the French authorities and to contest any wrongdoing on its part, and reaffirmed its commitment to meeting its tax obligations in France and in each of the countries where it operates. Its position when the senators took evidence in 2022 was that it pays corporate income tax in France, testimony they said required referral to the public prosecutor.
Why it matters: France has spent four years building a criminal theory on top of a parliamentary finding about transfer pricing, and it has now secured almost the whole estimated loss before proving any of it. Intragroup charges for brand, administration and seconded staff are ordinary features of multinational structure, and nothing about using them is improper in itself. What is disputed here is whether charges of this size left the right amount of profit taxable in France, and a seizure on this scale prices that dispute years before anyone answers it. It also puts a number on a question that began as a political one, when senators asked what the state was getting back from the consultancies it was paying.
Outlook: The seizure settles nothing about liability. The figures that would let a reader judge the estimate are the ones the prosecutors have not published: the tax years covered, the taxable results they believe should have been reported, the transfer pricing adjustment applied and the rates used to convert one into the other. Until those appear, the 96 percent ratio measures only the relationship between the assets now frozen and the prosecutors’ own current estimate. It is not a finding of guilt and it is not a tax assessment.
Sources: Reuters, AFP, French Senate, Parquet National Financier.
