International tax

Leaving France with a securities portfolio triggers the exit tax. Payment deferral, annual follow-up and relief: how to secure your departure.

Routing passive flows through a relay company no longer secures a favourable tax treaty: France applies the treaty of the beneficial owner's State of residence.

Interposing a foreign company to invoice your services does not set aside French tax where the service is personal. Article 155 A of the French tax code explained.

A foreign company run from France can be taxed in France under the place-of-effective-management rule. Exposure to corporate tax, VAT and undisclosed-activity penalties.

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