International taxation of companies

International company taxation concerns companies operating across national borders. Establishment of subsidiaries abroad, structuring international groups, cross-border financial flows or mobility of directors expose companies to complex tax rules and increased risk of recovery.

In this context, the support of an international corporate tax lawyer is essential to secure transactions and ensure tax compliance.

The Cabinet Edouard Pruvost supports French and international companies facing these challenges.

What is international corporate taxation?

International corporate taxation brings together all applicable rules when:

• a company operates in several states;
• a group holds subsidiaries or establishments abroad;
• dividend, interest or royalty flows are paid internationally;
• cross-border restructuring operations are envisaged.

It involves the application of domestic tax law, international tax treaties and European and international standards.

Key issues for companies

Taxation of profits and permanent establishments

International corporate taxation determines:

• the State competent to impose profits;
• qualification of a permanent establishment;
• the distribution of results among States.

Poor qualifications can lead to double taxation and significant adjustments.

Financial flows and tax treaties

Cross-border flows (dividends, interest, royalties) are subject to:

• Source deductions;
• specific treaty rules;
• economic substance requirements.

Inadequate structuring can lead to excessive taxation.

Transfer pricing and anti-abuse rules

International groups must respect:

• transfer pricing rules;
• documentation requirements;
• anti-abuse and anti-tax evasion devices.

These rules are subject to increased control by tax administrations.

Why be accompanied by an international tax lawyer?

Using a lawyer specializing in international corporate taxation allows:

• secure the structuring of international groups;
• anticipate cross-border tax risks;
• ensure declarative compliance;
• effectively defend society in case of control or tax litigation.

Accompaniment to the Cabinet Edouard Pruvost

The Cabinet Edouard Pruvost accompanies companies at every stage of their international development:

• Structure and location abroad;
• taxation of international flows;
• cross-border restructuring;
• international tax controls and disputes.

Each case is handled with a strategic and personalized approach.

Edouard Pruvost firm: your international corporate tax lawyer

Thanks to its technical expertise and in-depth knowledge of international taxation, Edouard Pruvost is a leading partner for companies facing international tax challenges.