Lawyer specializing in international tax convention

International tax treaties play a key role in the taxation of individuals, managers and businesses with interests in several States. In particular, they make it possible to distribute the power to impose between the signatory countries, to avoid situations of double taxation and to prevent certain conflicts relating to tax residence.

However, the application of an international tax convention may be complex. Each situation requires a thorough analysis of the tax residence, the nature of the income, the location of the assets and the provisions specific to the Convention concerned.

Edward Pruvost's firm assists individuals and businesses in the interpretation and application of international tax treaties.

What is an international tax convention?

An international tax convention is a treaty between two States to organize the distribution of their tax rights.

The main objectives of these conventions are to:

  • avoid double taxation;
  • prevent situations of double exemption or non-taxation;
  • determining tax residence when a person has links with several states;
  • allocate the right to tax different categories of income;
  • facilitate the exchange of information between tax administrations;
  • fight against tax fraud and tax evasion.

France has signed over 100 tax treaties with its main economic partners.

In which cases does a tax convention apply?

A tax treaty may include:

  • expatriation or return to France;
  • change of tax residence;
  • international teleworking;
  • professional activity in several countries;
  • foreign real estate income;
  • dividends, interest and royalties;
  • transfer of securities or undertakings;
  • property held abroad;
  • international succession;
  • international donation;
  • creation or detention of a foreign company.

In each of these situations, the applicable convention should be identified and the provisions correctly interpreted.

Why use a lawyer specialized in international tax conventions?

Tax treaties do not replace national laws. They overlap and must be interpreted in conjunction with French tax law, the law of the foreign State concerned and, where appropriate, the case law and administrative comments.

The intervention of a tax lawyer makes it possible to:

  • determine your tax residence;
  • identify the State having the right to impose;
  • prevent situations of double taxation;
  • secure international expatriation or mobility;
  • prepare an international heritage transmission;
  • assist companies in their international operations;
  • defending your interests during fiscal control or litigation.

The main international tax treaties

The firm regularly intervenes on the application of tax treaties concluded between France and many states.

Europe

  • Franco-German Tax Convention
  • Franco-Belgian Tax Convention
  • Franco-British Tax Convention
  • Franco-Spanish Tax Convention
  • Franco-Irish Tax Convention
  • Franco-Italian Tax Convention
  • Franco-Luxembourg Tax Convention
  • Franco-Monegasque Tax Convention
  • Franco-Dutch Tax Convention
  • Franco-Portuguese Tax Convention
  • Franco-Swiss Tax Convention

North America

  • Franco-American Tax Convention
  • Franco-Canadian Tax Convention

Asia

  • Franco-Chinese Tax Convention
  • Franco-Hong Kong Tax Convention
  • Franco-Japanese Tax Convention
  • Franco-Singapore Tax Convention

Africa

  • Franco-Moroccan Tax Convention
  • Franco-Mauritian Tax Convention

Middle East

  • Franco-Emirian Tax Convention

Oceania

  • Franco-Australian Tax Convention

Each agreement has specific features which should be understood in the light of your personal or professional situation.

Key issues addressed by tax treaties

International tax treaties address, inter alia:

  • Where am I a tax resident?
  • In which country do I have to pay taxes?
  • How to avoid double taxation?
  • Where are my property income taxed?
  • How are dividends and interest taxed?
  • How are capital gains taxed?
  • What tax convention is applicable to my situation?
  • How to resolve a tax residency dispute?
  • What are the effects of expatriation?
  • How are international successions imposed?

Why choose Edward Pruvost's firm?

The firm operates exclusively in tax law and supports a French and international clientele facing cross-border tax issues.

Our intervention includes:

  • analysis of international tax treaties;
  • determination of tax residence;
  • assistance in expatriation;
  • international investment;
  • Property taxation;
  • international successions;
  • international tax controls;
  • disputes before the tax administration and the competent courts.

Each case is analysed individually to identify the applicable convention, secure your tax situation and effectively defend your interests.

Contact your international tax lawyer and tax convention

Are you facing an international tax problem or want to know the consequences of a tax convention on your situation?

Edward Pruvost's firm assists you in the interpretation of international tax treaties, securing your cross-border transactions and defending your interests with the tax administration.

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