Technical papers

International taxation is the core of Alphard Law's practice and the largest section of our Perspectives.

Tax residence and treaties, exit tax and leaving France, foreign companies and trusts, non-residents owning property in France, permanent establishment and transfer pricing: each article starts from an issue met in practice and relies on the latest legislation and case law.

International tax

Matters

Gift Tax International tax Wealth Income tax Positions France-US Tax Desk

France 3% Tax: What the 2026 Reform Changes for Foreign Entities

International tax - Published on November 9, 2026

The 2026 reform of the French 3% tax and the Sweet Revenge, Satofi, Le Bois Dormant and Sefimo rulings: what foreign owners of French property must check before 15 May 2027.

French CFC Rules for Individuals: Article 123 bis After 2026 Rulings

International tax - Published on November 2, 2026

Preferential regime, financial assets, transparent entities: the three limits set by France's Conseil d'Etat on Article 123 bis and what they mean for Dubai.

French Tax Residence: Why a Foreign Certificate Is No Longer Enough

International tax - Published on October 26, 2026

Home, centre of economic interests, foreign certificates: what French appeal courts held in 2026 and how to plan a tax-defensible departure from France.

Foreign Trusts and Foundations: French Wealth Tax After 2026 Rulings

International tax - Published on October 19, 2026

One distribution from a foreign trust or foundation now brings all its real estate assets into the French IFI. What this means ahead of the 2027 disclosure facility.

Non-compete payment after expatriation: where is it taxed?

International tax - Published on October 12, 2026

A non-compete payment received after moving abroad remunerates an abstention, and may be taxable in the State of residence, not in France.

Matters

Gift Tax International tax Wealth Income tax Positions France-US Tax Desk