International tax lawyer
International taxation has become a major issue for individuals, managers, investors and companies whose situation exceeds French borders. Expatriation, impariation, foreign income, bank accounts held outside France, international investment, foreign companies or cross-border tax control: each situation requires a precise analysis of French tax law and international tax rules.
In this context, the international tax lawyer makes it possible to anticipate risks, secure a tax situation and defend the taxpayer's interests against the administration.
Master Édouard Pruvost, tax lawyer at the Paris Bar and Doctor of Tax Law, accompanies French and international clients in dealing with complex cross-border tax issues.
Since its activity is exclusively devoted to tax law, the Cabinet acts in both advisory and supervisory matters and in international tax disputes.
What is an international tax lawyer?
An international tax lawyer is a lawyer whose practice focuses on tax issues involving several states.
International taxation is not a completely separate right from domestic tax law. It results from the articulation of several sets of rules:
- French tax law;
- international tax treaties;
- European Union law;
- the rules applicable in the foreign States concerned;
- French and European case law;
- international mechanisms for the exchange of tax information.
This superimposition of standards makes international situations particularly complex.
For example, a person may be considered a tax resident under the domestic law of two States. The same income may also fall within the scope of taxation in several countries.
One of the tasks of the international tax lawyer is precisely to analyse these conflicts of rules in order to determine the applicable tax treatment.
Édouard Pruvost, international tax lawyer in Paris
Master Edward Pruvost is tax lawyer at the Paris Bar.
His professional activity is exclusively devoted to tax law.
He holds the Certificate of specialization in tax law issued by the National Bar Council and is also Doctor of Tax Law.
This dual vocational and university training allows him to address international tax issues with in-depth legal analysis.
The Cabinet includes:
- individuals with income or assets abroad;
- expatriates and future expatriates;
- Imperates moving to France;
- Leaders operating in several countries;
- international investors;
- families with an international heritage;
- companies carrying out cross-border operations.
Each case shall be analysed individually taking into account the situation of the client, the States concerned and the applicable tax treaties.
Why consult an international tax lawyer?
An international tax situation can quickly raise several issues.
In which country am I resident in tax?
Where do I report my income?
Should an income already taxed abroad also be declared in France?
How to avoid double taxation?
Do I have to report my foreign bank account?
What are the tax consequences of leaving France?
How can we respond to a control over foreign income or assets?
These issues cannot generally be dealt with solely by reading the General Tax Code.
The analysis often involves studying International Tax Convention and to determine precisely the legal qualification of each income or asset.
To consult an international tax lawyer, a comprehensive analysis of the situation can be made and decisions made can be secured.
International tax residence: determining your tax country
Tax residence is one of the main problems encountered in international taxation.
Living a part of the year abroad does not necessarily mean that one ceases to be a French tax resident.
Conversely, a person living in France may retain important economic or heritage ties with another State.
French tax law uses several criteria to determine the tax domicile of a taxpayer.
Where two States simultaneously consider a person to be a tax resident, it is necessary to examine the tax treaty between the countries concerned.
Tax treaties generally provide for a succession of criteria for resolving dual residence situations.
The international tax lawyer analyses in particular:
- the taxpayer's home;
- his place of residence;
- the centre of its economic interests;
- his professional activity;
- personal and heritage ties;
- the provisions of the applicable tax convention.
Determining tax residence is essential as it can condition the taxation of all the taxpayer's global income.
International tax lawyer and expatriation
A departure from France must be anticipated in fiscal terms.
Expatriation can have an impact on the taxation of income, wealth and capital gains.
Before the transfer of tax residence, the tax lawyer may carry out a tax audit of the taxpayer's situation.
This analysis may include:
- the effective date of the transfer of tax residence;
- the application of the international tax convention;
- taxation of income before and after departure;
- the tax consequences of holding companies;
- the possible application of exit tax;
- taxation of real estate held in France;
- reporting obligations remaining after departure.
A well-prepared expatriation allows for the identification of fiscal difficulties before they become contentious.
Cabinet supports taxpayers in the preparation and tax security of their expatriation.
Taxation of tax-payers and return to France
The installation or return to France also raises specific tax issues.
A taxpayer who comes to work in France may, under certain conditions, benefit from the tax system of the impoverished.
The scheme provides for special rules concerning certain elements of remuneration and certain income from foreign sources.
The intervention of an international tax lawyer makes it possible to analyse the conditions of application of the scheme and to secure the reporting arrangements.
The Cabinet also accompanies people returning to France after several years abroad.
A return to France may require a prior analysis of international assets, foreign companies, bank accounts and income collected outside France.
Foreign income: what tax obligations in France?
French tax residents are, in principle, taxable in France on their world income, subject to international tax treaties.
Foreign income may include:
- wages received abroad;
- dividends from foreign companies;
- interest from foreign accounts;
- real estate income outside France;
- gains realized abroad;
- foreign pensions;
- income from an international activity.
The declaration of such income requires the identification of their legal nature and the application of the relevant tax treaty.
Depending on the situation, the Convention may provide for an exemption in France, the application of a tax credit or other mechanism to eliminate double taxation.
Misqualification may result in incorrect taxation or tax control.
The international tax lawyer can analyse foreign income and secure its processing in French tax declarations.
Double taxation and international tax treaties
International tax treaties play a central role in cross-border taxation.
France has concluded numerous conventions with foreign States.
In particular, these laws determine which State has the right to impose certain categories of income.
These include:
- salaries;
- real estate income;
- dividends;
- interests;
- fees;
- capital gains;
- pensions.
The application of a tax convention requires a precise legal analysis.
It is not enough for a tax to have been paid abroad to automatically consider that income must not be declared in France.
In many situations, income must be reported in France and a specific mechanism can then eliminate double taxation.
The international tax lawyer verifies the applicable convention and determines the tax treatment of the income concerned.
Foreign bank accounts and reporting obligations
Holding a bank account abroad may result in reporting obligations in France.
These obligations apply to many taxpayers with accounts opened with foreign financial institutions.
The automatic exchange of information between tax administrations has considerably strengthened the ability of the French administration to identify financial assets held outside France.
Failure to report a foreign account may result in sanctions and, in some situations, fiscal control.
The Cabinet assists taxpayers who wish to analyse or regularize their tax status with respect to accounts held abroad.
The intervention of the tax lawyer makes it possible to study the origin of the funds, the history of the account and the possible tax consequences before any procedure with the administration.
International taxation of assets
The holding of a heritage distributed in several countries raises specific problems.
Real estate abroad, equity interests in foreign companies, international bank accounts or property structures require a coordinated analysis.
In particular, the Cabinet intervenes on matters relating to:
- tax on property;
- taxation of foreign real property;
- international heritage income;
- international capital gains;
- international donations and successions;
- the structuring of a cross-border heritage.
International taxation of assets requires anticipating the tax consequences in the various States concerned.
International business taxation
Companies operating internationally face specific tax issues.
Setting up in another country, setting up a subsidiary or making international financial flows can profoundly change the tax situation of a group.
The international tax lawyer assists companies in the analysis of their cross-border transactions.
Issues may include:
- international tax structure;
- permanent establishments;
- dividend flows;
- interest and royalties;
- Source deductions;
- transfer prices;
- the establishment of a foreign company in France;
- the international development of a French company.
The aim is to legally secure transactions and anticipate the risks of tax administrations questioning.
International tax control
Tax controls involving foreign elements have developed considerably.
The tax administration now has many mechanisms for exchanging information with foreign administrations.
International tax control may include:
- the taxpayer's tax residence;
- undeclared foreign income;
- foreign bank accounts;
- assets held outside France;
- international financial flows;
- foreign companies or structures.
In this context, the assistance of an international tax lawyer makes it possible to analyse the demands of the administration and to build an appropriate defence strategy.
Master Edward Pruvost intervenes in the framework of the tax controls and international tax disputes.
The Cabinet assists the taxpayer in dealing with the tax administration and defends it when the proposed corrections are questionable.
Regularize an international tax situation
Some people find late that they have not properly fulfilled their tax obligations in France.
This may include foreign income or bank accounts held outside France.
In this situation, it is recommended that the file be analysed precisely before contacting the tax administration.
International tax regularization must be prepared.
The tax lawyer examines in particular:
- the years concerned;
- the nature of the income;
- declarations already filed;
- the origin of the funds;
- applicable tax treaties;
- any taxes paid abroad.
This analysis is used to determine the most appropriate regularization strategy for the taxpayer.
When to contact an international tax lawyer?
It is advisable to consult an international tax lawyer whenever a personal, professional or property situation involves several countries.
Intervention can be particularly useful before:
- a departure from France;
- a return or installation in France;
- a real estate investment abroad;
- the collection of foreign income;
- the creation of an international company;
- restructuring involving several countries;
- International heritage transmission.
It is also recommended that a lawyer be consulted promptly in the event of a request for information or control of the tax administration concerning foreign elements.
The earlier the analysis takes place, the more it is possible to anticipate and secure the tax situation.
Why choose Master Edward Pruvost as an international tax lawyer?
International taxation requires thorough control of tax law and an ability to analyse complex legal situations.
Master Édouard Pruvost practises exclusively in tax law.
A tax lawyer at the Paris Bar, he holds the Certificate of specialization in tax law issued by the National Bar Council.
It is also Doctor of Tax Law.
For several years, the Cabinet has been supporting individuals, executives, investors, families and businesses facing high-level tax issues.
The Cabinet approach is based on an in-depth analysis of each case and the definition of a tax strategy tailored to the client's situation.
The Cabinet intervenes in France and on tax issues with an international dimension.
Contact an international tax lawyer
Are you expatriate, non-resident, or impatriate?
Do you earn income abroad?
Do you have bank accounts or assets outside France?
Does your company carry out international operations?
Are you subject to fiscal control over foreign elements?
Master Édouard Pruvost, tax lawyer and Doctor of Tax Law, analyzes your situation and accompanies you in the treatment of your international tax issues.
The Cabinet is located in Paris and works with a French and international clientele.
Contact Cabinet for a personalized analysis of your international tax situation.
Frequently asked questions about international tax lawyer
What is the role of an international tax lawyer?
The international tax lawyer advises and defends individuals and businesses facing tax issues involving several countries. It analyses tax residence, tax treaties, foreign income and the risk of double taxation.
When to consult an international tax lawyer?
It is recommended to consult before an expatriation, impariation, international investment or when you receive foreign income. The intervention of a lawyer is also particularly important in case of international tax control.
Do I have to report my foreign income in France?
A French tax resident is in principle required to report his world income. The tax treatment then depends on the nature of the income and the tax agreement concluded between France and the State concerned.
How to avoid double taxation?
International tax treaties provide mechanisms to eliminate or limit double taxation. Their application depends on the country concerned and the nature of the income.
Can a tax lawyer regularize an undeclared foreign account?
Yes. The tax lawyer can analyse the history of the account, the origin of the funds and the tax consequences in order to prepare an appropriate regularization approach.
Which lawyer to choose for a tax expatriation?
It is preferable to consult a lawyer whose activity is specifically devoted to tax law and who has an international tax practice. The Cabinet, which specializes in international taxation, has been assisting taxpayers in tax expatriation for several years.
