International tax lawyer
Individual mobility, cross-border flows, investments abroad: international tax requires command of both domestic law and treaties. The firm advises individuals, executives and companies on their international transactions and structures, with particular expertise in French–Luxembourg taxation.
Applying tax treaties
- Determining and transferring tax residence
- Eliminating double taxation (tax credit, exemption)
- Withholding tax on dividends, interest and royalties
- Mutual agreement procedures between tax authorities
- Voluntary disclosure of foreign accounts and assets
Mobility and international structuring
- Structuring cross-border investments (holdings, SOPARFI, SCI)
- International mobility of executives: exit tax, inbound regime
- International real estate holdings
- Transfer pricing and substance of foreign structures
- Wealth transfer involving foreign elements
France–Luxembourg axis
- Cross-border workers: remote work and the 34-day rule, dual filing
- France–Luxembourg tax treaty of 20 March 2018
- Tax assimilation to Luxembourg residents (article 157ter LIR)
- Financial participation companies (SOPARFI): participation exemption
- Luxembourg pensions, stock options and incentive plans