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.
Recommended reading:
International tax
Exit tax: payment deferral and filing duties on departure
International tax - Published on July 20, 2026, updated on November 2, 2026
Leaving France with a securities portfolio triggers the exit tax. Payment deferral, annual follow-up and relief: how to secure your departure.
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Beneficial owner: which tax treaty applies to passive flows?
International tax - Published on July 13, 2026, updated on November 2, 2026
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.
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Billing your services through a foreign company: article 155 A
International tax - Published on July 6, 2026, updated on August 18, 2026
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.
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Foreign company run from France: the tax exposure
International tax - Published on June 29, 2026, updated on August 18, 2026
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.
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Undeclared Foreign Assets: France's 60% Levy Under Challenge
International tax - Published on June 22, 2026, updated on August 18, 2026
France's L. 23 C / 755 mechanism taxes undeclared foreign assets at 60%. Courts now split over whether it amounts to de facto imprescriptibility.
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