International taxation

Companies and the people who run them are becoming increasingly mobile.

Therefore, when determining the most appropriate tax solutions, account must be taken of European taxation and international treaties, which are designed both to avoid double taxation and to combat fraud and tax evasion.

Thanks to our experience in this field, we can incorporate this international dimension into your tax decisions.

We work with first-rate foreign correspondents with whom we have established privileged relationships.

Scope of services

We support you in your decisions that have an international impact by liaising with a network of first-rate correspondents in Europe and elsewhere.

In particular, we have recognised experience in direct Community taxation (freedom of establishment, free movement of capital, directives, etc.).

We work in the following areas in particular:

Photo illustrated by residence transfers

Transfers of residence

We help clients who wish to establish their tax residence outside France, whether in the EU or outside the EU.
We can advise them on the steps to be taken, both before and after the transfer, to ensure that the transfer cannot be challenged by the French tax authorities.
We can prepare exit tax returns for those concerned and monitor them for as long as the tax applies to them.

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Thanks to our network of foreign correspondents, we can ensure the transfer to the destination country is optimised from the tax point of view.
We represent expatriates before the French tax authorities.
In the opposite direction, we assist people who wish to settle in our country and ensure that they are fully informed about their tax obligations.
If eligible, we ensure that they benefit from the tax regime for inpatriates.

Real estate investments in France

We help people who wish to invest in real estate in France, whether for professional or residential purposes, to determine the most efficient structure possible given the particularities of the tax regime applicable to them.
We have established relationships of trust with recognised professionals (including notaries, chartered accountants and real estate agents) which make it possible to optimise the management of these assets over time.

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We offer solutions to ensure that these assets are passed on as efficiently as possible, particularly in the context of a transfer within a family.

Photo illustrated by international taxation in France.

Direct Community Taxation

We have acquired recognised experience in direct Community taxation, notably as a result of litigation in this field before national and EU courts:
- Challenging the exit tax (Lasteyrie du Saillant, Gibier, Aube-Martin cases)
- Capital gains tax regime and reverse discrimination (Marc Jacob case)

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We apply the main principles of EU law (freedom of establishment, free movement of capital, parent-subsidiary and merger directives) in the disputes between our clients and the tax authorities.
We participate actively in the EU Tax Group, which brings together the best European specialists in EU law, and are regularly invited to conduct seminars on developments in EU law.

Yachting / Sailing

We assist our clients in relation to the construction (mostly by foreign shipyards) or acquisition of pleasure craft.
We determine with our clients the tax regime that will apply to them depending on how the craft will be used (particularly with regard to VAT).

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We guide them on whether to choose an EU or non-EU flag for these vessels.
Together with leading shipbrokers, we organise the commercial operation of these ships if necessary.
We assist our clients in the event of disputes with tax or customs authorities concerning the regime applicable to these vessels.
We edit the "Yachting" tax section of the Droit Maritime Français magazine.

References

Julien Bellet
Lawyer at the New York Bar
Eric Chartier
Lecturer at the University of Dijon (Community taxation)
Eric Ginter
Lecturer at Paris-Dauphine (Community taxation)

International taxation

Scope of services

Transfers of residence

Real estate investments in France

Direct Community Taxation

Yachting / Sailing

References

Julien Bellet

Eric Chartier

Eric Ginter