French-British tax lawyer: mobility, assets and operations between France and the United Kingdom
Between France and the United Kingdom, taxation can directly affect the timing of an assignment, the way in which an asset is held, the choice of a residence or the flow of certain income.
The Franco-British Convention distributes the power to impose between the two states and organizes the treatment of many categories of income and capital gains. In the case of significant assets or transactions, its interest lies mainly in the way it is linked with the French and British internal rules.
Sequencing a transaction may change its tax result
A transfer of residence, distribution, transfer of securities or realization of surplus value before or after mobility does not necessarily produce the same result.
The tax strategy then consists of comparing several possible sequences: determining when to complete the transaction, under what structure, with what detention and with what consequences in each of the two States.
This logic is particularly important where the assets include companies, real estate assets or interests whose value is likely to be realized in the short or medium term.
Arbit according to the value actually stored
In a Franco-British situation, the facial rate of a tax is not sufficient to assess the effectiveness of a choice. Deductions at source, tax credits, income tax and property rules can substantially change the net result of the transaction. In particular, the Convention lays down specific rules for property income and capital gains.
The firm intervenes on these arbitrations to design structurings to exploit the available favourable mechanisms and to optimize the overall tax burden in compliance with the applicable rules.
Master Edouard Pruvost specializes in international tax strategy advice. To organise a mobility, divestiture or heritage structure between France and the United Kingdom with a clear vision of its fiscal impact, contact the firm to define the strategy best suited to your objectives.
