Navigating the tax implications of cross-border assets.

When an individual's life, assets, or a company's operations span multiple countries, a global understanding of tax issues becomes essential.

Living, investing, or conducting business in multiple countries multiplies tax obligations and the risks of double taxation. Without prior coordination, seemingly simple situations quickly become complex:

• a French resident holding assets abroad;
• an executive temporarily relocating their business;
• a family whose heirs are spread across several countries.

Tax residency: the first question

The first step often involves clarifying tax residency. French criteria, treaty definitions, and administrative practices are not always aligned. This classification has immediate and lasting consequences: primary country of taxation, scope of reporting obligations, and whether exit tax applies. We conduct a precise analysis of your situation to provide you with clear visibility.

Bilateral tax treaties

Tax treaties are the primary tool for coordination between states. However, they must be interpreted correctly: their scope, rules for allocating taxing rights, mechanisms for eliminating double taxation, and anti-abuse clauses. We apply this treaty interpretation to each case, taking into account French and international case law, as well as administrative positions.

Structuring International Flows

Structuring flows across multiple countries requires particular attention:

• dividends received from a foreign subsidiary;
• management fees charged to a related company;
• trademark or patent royalties.

Rules regarding transfer pricing, economic substance, withholding taxes, and anti-abuse provisions have become more stringent. Our approach is to build structures that are sustainable in the long term and withstand scrutiny.

Expatriation and Inpatriation

These transitions raise very practical questions:

• which assets to move or retain?
• what tax regime applies to income earned abroad?
• how to manage exit tax and reporting obligations?

For inpatriates in France, the specific regime offers opportunities provided its conditions are strictly met. We assist with these transitions end-to-end.

For expatriations, we have a network of correspondents in several countries with whom we regularly work. 

International Estate Planning

For families with ties in multiple countries, international estate planning is a distinct area of expertise. Private international law rules, inheritance conventions, and the specific inheritance regimes of each country combine. We work with local correspondents to build a coherent strategy for your family.

Who We Serve

Our firm advises mobile executives, international investors, families whose children have settled abroad, and foreign individuals moving to or leaving France. Each situation requires a specific analysis and close coordination between legal, tax, and wealth management dimensions.