Barreau de Paris

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 a particular focus on French-Luxembourg taxation.

The most frequent situations

Tax residence in France: how it is determined and proved The domestic criteria, the treaty tie-breaker, and the evidence expected.
Eliminating double taxation: credit or exemption How a treaty removes double taxation, and what to do when it persists.
Withholding tax: dividends, interest, royalties Domestic rate, treaty reduction, European exemptions, and how to obtain a refund.
Mutual agreement procedure between tax authorities When neither State gives way: the mutual agreement procedure, its deadlines, its outcome.
Regularising undeclared foreign accounts and assets Fines, extended assessment period, criminal exposure, and how to conduct a regularisation.
Structuring a cross-border investment Choosing the structure of an international investment, and giving it real substance.
Exit tax and the inbound regime: leaving, returning What leaving France costs, what returning saves, and the conditions of both regimes.
Holding property abroad, or in France from abroad Non-resident owning in France, or French resident owning abroad: both directions.
Transfer pricing and substance of foreign entities The documentation duty, adjustments under article 57, and the substance expected.
Passing on assets with a foreign element Which State taxes what when the deceased, the heir or the asset is abroad.
Cross-border workers in Luxembourg: tax and filings Where the salary is taxed, the teleworking threshold, and what to file in France.
The France-Luxembourg treaty of 20 March 2018 Which State taxes what between the two countries, and how double taxation is removed.
Being taxed as a Luxembourg resident (article 157ter) Being taxed in Luxembourg as a resident: conditions, benefit, and effect in France.
SOPARFI: what a French resident should check The participation exemption, the substance required, and the French tax view.
Luxembourg pensions, stock options and incentive plans Pension, stock options, incentive plan: which State taxes, when, and what to declare.

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

Analyses from the firm

All articles

Articles are currently published in French; English versions are available on request.

Describe your situation

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Phone: +33 6 20 75 75 61
WhatsApp: Message the firm
The firm: 56 avenue Kléber
75116 Paris
Languages: French, English, German. At the office or by video call.

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