Perspectives

France's L. 23 C / 755 mechanism taxes undeclared foreign assets at 60%. Courts now split over whether it amounts to de facto imprescriptibility.

French and treaty residency tests, the nationality clause, 2026 Andorran permits, exit-tax deferral with security, and seat transfers: the Alphard Law method.

The dispute over France's 3% tax has shifted from property value to transparency over the holders. State of play and impact of the 2027 reform.

The French Government's reply on SASU social levies ignores Article L. 136-3 CSS and the Paris Court of Appeal ruling.

Analysis of the French tax regime for manual gifts: disclosure as the taxable event and its territorial consequences for non-residents relocating to France.