International taxation of assets

International taxation of wealth is today at the heart of the concerns of wealthy individuals, leaders, entrepreneurs, investors and international families. Increased mobility, expatriation, cross-border investment, holding assets abroad or international heritage transmission expose taxpayers to complex tax issues and high legal risks.

In this context, the accompaniment by a law firm specializing in international taxation of assets is essential to secure operations, prevent litigation and optimize the structure of assets in compliance with French and international regulations.

The Cabinet Edouard Pruvost supports its clients on all these issues with recognized expertise in international property taxation.

What is international taxation of wealth?

International taxation of assets includes all the tax rules applicable when a person's assets have one or more extraneous elements.

Situations concerned

Among other things, international taxation of assets includes:

• tax residence outside France or in dual residence;
• the holding of real estate assets located abroad;
• foreign financial investments and bank accounts;
• International heritage structures (holdings, trusts, foundations);
• international successions and donations.

These situations involve the articulation of several national tax laws, international tax treaties, as well as European and international standards (OECD, BEPS, CRS, FATCA).

The main challenges of international taxation of wealth

Determination of tax residence

Tax residence is the entry point for any analysis of international wealth taxation. It conditions:

• the extent of taxation (global or territorial);
• the application of international tax treaties;
• the taxpayer's reporting obligations.

Misqualification of tax residence may result in significant tax adjustments, with penalties and interest on late payment.

International taxation of wealth and income

International taxation of assets includes:

• income tax (foreign income, withholding tax);
• Property tax (IFI) on property situated in France or held via foreign structures;
• taxation of capital gains on real estate and international securities;
• taxation of foreign financial investments.

Each asset category should be analysed in the light of applicable tax treaties in order to avoid double taxation.

International taxation of inheritances and donations

International transmissions are among the most sensitive topics in international heritage taxation.

High tax risks

International successions and donations may result in:

• simultaneous application of several transfer rights;
• double or even triple taxation;
• complex tax rules related to the residence of the deceased, donor or heirs;
• a specific treatment of foreign trusts and foundations.

An international heritage anticipation is essential to secure transmission and preserve family interests.

International reporting obligations

International taxation of wealth implies greater tax transparency.

Mandatory declarations

These include:

• bank account declarations held abroad;
• life insurance contracts outside France;
• interests in foreign companies;
• trusts and similar structures.

Failure to comply with these obligations can result in very heavy financial penalties, regardless of fraudulent intent.

Cabinet expertise Edouard Pruvost in International Wealth Taxation

A comprehensive and strategic approach to international heritage

The Edouard Pruvost Cabinet accompanies its clients at every stage of their international heritage life:

• International heritage structure;
• expatriation and impariation;
• real estate and financial investment abroad;
• International transmission and succession;
• tax compliance and declaratory security.

The approach is comprehensive, integrating fiscal, legal and heritage dimensions.

Recognized expertise in international taxation

The firm intervenes in particular on:

• conflicts of tax residence;
• the application and interpretation of international tax treaties;
• taxation of foreign heritage structures;
• assistance in international tax controls;
• international tax disputes.

Each case benefits from a tailor-made analysis based on a constant legal and fiscal watch.

Demanding international clientele

The Cabinet Edouard Pruvost accompanies in particular:

• international leaders and entrepreneurs;
• families with a cross-border heritage;
• expatriates and unmarried persons;
• foreign investors in France;
• heirs facing complex international successions.

Confidentiality, legal certainty and technical rigour are the cornerstones of the firm's intervention.

Why call on an international wealth tax lawyer?

International taxation of wealth is a highly technical, evolving and financially challenging area.

Accompaniment by a specialist lawyer enables:

• anticipate and control international tax risks;
• avoid situations of double taxation;
• secure complex heritage operations;
• effectively defend its interests in the event of control or litigation;
• optimize heritage structure within a strictly legal framework.

Edouard Pruvost: a reference partner in international wealth taxation

Thanks to its sophisticated expertise and a personalized approach, Edouard Pruvost has established itself as a leading player in international wealth taxation.

The firm accompanies its clients rigorously, discreetly and efficiently, whether it be international heritage structure, transmission, tax compliance or litigation.