International tax

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.

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

How to articulate the Italian D.Lgs. 139/2024 reform, the 1990 France-Italy convention and the German § 21 ErbStG credit to optimise cross-border gifts from Italy.