International tax assembly

Design structures adapted to cross-border operations

International tax structure consists of the legal organization of a transaction, investment or group of companies, taking into account the tax rules applicable in each jurisdiction concerned. Implementation abroad, establishment of a holding company, acquisition of a foreign company, international development of a company or organisation of a cross-border asset require a coordinated analysis of domestic tax law, international tax treaties, EU law and OECD standards.

The objective of fiscal structuring is not to seek an isolated tax advantage. It consists of ensuring the legal, economic and fiscal coherence of a transaction in an environment where several tax administrations are likely to exercise their tax power simultaneously.

An approach based on legal certainty

Any international operation involves interactions between several tax systems. Source deductions, transfer pricing, permanent establishment rules, anti-abuse schemes, controlled foreign companies or international reporting obligations must be integrated from the outset of the design of the structure.

A prior analysis is needed to anticipate the risks of double taxation, to identify the constraints specific to each state and to assess the fiscal consequences that could affect the transaction in a sustainable manner. The structure thus takes place prior to strategic decisions to ensure their sustainability.

Solutions adapted to international operations

The firm intervenes in the structuring of international groups, the creation of holding companies, cross-border acquisitions, international real estate investments, mobility operations of managers and heritage reorganization projects with an extraneous element.

Each case shall be analysed individually taking into account the economic objectives pursued, the organisation of the group or the assets and the interactions between the different tax laws applicable.

Expertise in international taxation

The firm supports corporate groups, executives, investors and international families in designing and securing their cross-border operations. Its intervention covers the legal and tax structure of investments, the application of international tax treaties, the anticipation of double taxation risks and assistance in cases of international tax control or litigation.

The structure of international operations is based on a constant requirement: to reconcile the client's economic objectives with the rules applicable in each jurisdiction in order to ensure the security and sustainability of the choices chosen.