Lawyer specializing in international tax litigation

The use of a tax lawyer specializing in international tax litigation is decisive when the taxpayer is confronted with a dispute with the tax administration concerning transactions or situations with an international dimension.

Such litigation usually involves high financial issues, complex legal issues and a significant risk of double taxation or tax sanctions.

International tax disputes arise, inter alia, following tax controls on cross-border flows, transfer prices, the existence of stable institutions, the application of international tax treaties or anti-abuse measures. Their treatment requires thorough control of domestic tax law, international tax law and administrative litigation.

In this context, the intervention of a lawyer specializing in international tax litigation enables the construction and defence of a coherent and effective legal strategy, both at the pre-contentious stage and before the competent courts.

Expertise in complex international tax litigation

Master Édouard Pruvost, a tax lawyer at the Paris Bar, devotes his entire activity to tax law. He holds the Certificate of Specialisation in Tax Law issued by the National Bar Council (CNB) and a Doctorate in Tax Law, attesting to a thorough and recognized technical expertise.

It intervenes in tax disputes with a marked international dimension, particularly when the tax administration questions:

• international distribution of profits and transfer pricing policies;
• the existence of a permanent establishment in France or abroad;
• the application, interpretation or scope of international tax treaties;
• tax classification of cross-border flows (dividends, interest, royalties, management fees);
• the application of withholding taxes and anti-abuse mechanisms;
• conformity of international tax structures or schemes.

Areas of intervention in international tax litigation

Cabinet intervenes at all stages of international tax litigation, including through:

• contesting tax adjustments resulting from international controls;
• preparation and filing of contentious claims;
• Pre-contentious trade with the tax administration;
• hierarchical appeals and referral to advisory commissions;
• procedures before the courts;
• the management of double taxation risks and the articulation of international procedures.

Each case is the subject of a comprehensive analysis, incorporating tax, treaty, procedural and litigation issues specific to international situations.

A contentious strategy built prior to the tax dispute

International tax litigation is often the result of deep technical disagreements between the taxpayer and the tax administration.

The approach adopted is to develop a rigorous and defensible contentious strategy based on a thorough analysis of tax legislation, international conventions, administrative doctrine and French and European case law.

This strategy is designed from the early stages of the tax dispute, in order to secure the taxpayer's positions and optimize the chances of success before the competent courts.

Institutional recognition in tax law and international taxation

The expertise of Maître Édouard Pruvost is recognized institutionally and academicly.

These include:

• Chairman of the jury for the examination of the Certificate of Specialisation in Tax Law at the École de Formation du Barreau de Paris (EFB);
• Member of the Institute of Tax Lawyers (IACF), which brings together recognized tax law practitioners.

He regularly intervenes in higher education and the training of law and numeracy professionals, and publishes in specialized reference journals, in particular on issues of tax litigation and international taxation.

Strict and tailor-made support in international tax litigation

Calling on Maître Édouard Pruvost is a strategic, rigorous and personalized support in international tax disputes with strong financial and legal challenges.

The Cabinet intervenes in cases requiring a high level of expertise in international tax litigation, full control of conventional mechanisms and a comprehensive litigation vision, in order to defend the interests of taxpayers in the face of tax administration.