International tax lawyer

Taxation is a subject that often has to deal with situations involving different tax systems and deal with possible double taxation generated on the same transactions.

The tax consequences of the international mobility of people and goods are often difficult to grasp due to the development of technologies and the dematerialization of the economy. Added to this are the increasingly heavy economic constraints on the budgets of states seeking both to attract talent and investment and to have their budgets financed by foreigners who do not vote....

This environment creates numerous traps and obstacles that must be mastered to avoid serious setbacks. Nevertheless, it also brings opportunities. The tax lawyers of AlterTax accompany their clients, individuals and companies, in their international development by helping them define and implement a winning international tax strategy.

They also ensure the compliance of their operations with the French and foreign tax environment in order to secure their investments abroad and control their tax risk.

They can thus limit the tax exposure of French companies that have developed activities or own assets in Europe or abroad or of foreign companies operating in France or holding assets there.

The mastery of French tax rules, European law and bilateral tax treaties allows AlterTax Avocats' lawyers to propose solutions to their clients in order to avoid double taxation of the same tax base but also to optimize the effective rate of their global taxation.

AlterTax Avocats, experts working alongside companies

Our team of tax lawyers provides assistance to companies in the following areas

  • Assistance and advice for the establishment of French companies abroad or foreign companies in France
  • The modalities and the choice of setting up structures or activities in France or abroad by securing the latter, in particular in terms of corporate tax (analysis of the risk of qualification of a permanent establishment)
  • Management of international flows (dividends, royalties, interest, capital/debt investment ratio) and their fiscal impacts
  • Setting up structures for the acquisition of assets or companies abroad as part of external growth operations
  • Optimization of the effective tax rate of international groups
  • Support for the staff mobility policy
  • Securing treaty mechanisms to eliminate double taxation
  • Obtaining permanent establishment or regularization of tax situation with the French tax authorities
  • Establishment of remuneration streams for intangible assets (royalties) and preferential tax regimes for intellectual property
  • Implementation of service and merchandise flows (VAT and transfer pricing justification)

AlterTax Avocats, a team at the side of individuals

For individuals, our assistance includes

 

  • Analysis of tax residence criteria and securing tax residence in a single state. Analysis of the income that can be linked to France for activities carried out in France and abroad. Establishment of documentation and justification elements and tax returns;
  • Structuring and declaration of artists' and sportsmen's incomes within the framework of their participation in events in France and abroad (determination of income distribution rules, tax declarations, VAT analysis on event revenues, etc.);
  • Analysis of the rules of connection and distribution of income for activities of a liberal nature (BNC) carried out in France and abroad;
  • Structuring of investments in real estate assets located in France or abroad (holding methods, taxation of the various income streams, deductibility of acquisition debts), both in terms of registration fees and income tax (and withholding tax), the real estate wealth tax (IFI)
  • The holding of French or foreign holding or investment companies (dividend flows, interests) with respect to corporate income tax and income tax
  • Sale or transfer of assets held in France or abroad
  • The establishment of tax returns (income tax, withholding tax...)

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Cyril Maucour, tax lawyer with AlterTax

Cyril Maucour international tax lawyer based in Paris

I'm Cyril Maucour, Managing Partner of AlterTax, with over 20 years' experience in international taxation. I specialize in assistance with tax audits and litigation, offering my services to a varied international clientele, including entrepreneurs, SMEs and ETIs in various sectors such as industry, new technologies and pharmaceuticals. My multi-sector expertise enables me to provide effective advice to any company in need of an expert international tax lawyer.

It's good to be informed, but it's even better to be accompanied by an expert tax lawyer. Let's get in touch.

FAQ on international taxation

Here are some frequently asked questions about international taxation:

What is the role of an international tax lawyer?

An international tax lawyer specializes in tax law applicable to cross-border transactions and operations. He advises on tax compliance, structuring international operations, and helps navigate the tax regulations of different countries.

When should I consult an international tax lawyer?

It is advisable to consult an international tax lawyer when expanding your activities abroad, for international investments, or when facing complex tax issues involving several jurisdictions.

How can an international tax lawyer help my company?

He can help you plan and structure your international activities in a tax-efficient way, advise you on tax treaties, and ensure that you comply with tax laws in all the countries concerned, thereby reducing the risk of penalties and tax reassessments.

Can an international tax lawyer handle international tax disputes?

Yes, these lawyers are equipped to handle international tax disputes, including representation before tax authorities and courts in various countries, and to negotiate agreements with foreign tax authorities.

Is international taxation only relevant for large companies?

No, international taxation concerns any company or individual engaged in commercial activities or investments abroad, whatever its size. International tax rules can affect SMEs, start-ups and large multinationals alike.

How can an international tax lawyer help with double taxation?

The lawyer can advise you on the application of tax treaties to avoid double taxation and optimize the overall tax burden of your international activities, ensuring efficient use of tax credits and tax structures.

Can't find the answer you're looking for? Check out our articles on international taxation!

France's tax police: towards a repressive tax policy

The fight against tax fraud has become a major concern for tax authorities in France. To address this issue, the government has introduced a new tool: the tax police. This measure is an important step in the crackdown on tax crime, which is becoming increasingly severe. In this article, we look at the introduction of the tax police in France and its impact on tax policy, as well as the importance of calling on the services of a tax lawyer specialized in criminal tax matters.

Control of registration fees by the tax authorities

This control can generally lead to a rectification of the prices or evaluations retained within the framework of documents subjected to the formality of the registration (those are numerous and include in particular the operations relating to movable and immovable goods (gift, transfer, succession in particular but also IFI).

What debts are deductible for the IFI?

Debts on taxable (real estate) assets are deductible from the value of those assets for IFI purposes. However, this deductibility is excluded by law if the debts are not related to the taxable real estate assets. This is the case, for example, for debts incurred to ensure the family's lifestyle, to acquire non-taxable assets (a business, for example) or exempt assets (for example, premises constituting a taxpayer's professional tools).

How should Canadian trust assets be taxed?

How should Canadian trust assets be taxed?

For several years, the French tax authorities have been interested in various cases of potential tax fraud involving large French fortunes. These wealthy individuals would have used Canadian trusts, via the Blue Bridge asset management company, to avoid paying French wealth tax.
However, by a decision n°21/10189 of February 6, 2023, the Court of Appeal of Paris considered that the assets of a Canadian trust were only taxable in Canada and not in France, thus excluding the possibility of a tax fraud. Explanation.