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

Moving to Andorra: French Tax Residency, Exit Tax and Restructuring

Moving to Andorra: French Tax Residency, Exit Tax and Restructuring

French and treaty residency tests, the nationality clause, 2026 Andorran permits, exit-tax deferral with security, and seat transfers: the Alphard Law method.
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France's 3% Real-Estate Tax: Litigation and 2027 Reform

France's 3% Real-Estate Tax: Litigation and 2027 Reform

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.
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Italy-Germany-France cross-border gifts: 2026 tax guide

Italy-Germany-France cross-border gifts: 2026 tax guide

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.
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Foreign Trusts: Three Major French Tax Decisions from Q1 2026

Foreign Trusts: Three Major French Tax Decisions from Q1 2026

Analysis of three landmark Q1 2026 decisions reshaping the tax landscape for French-resident trust beneficiaries.
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French Real Estate for Non-Residents: IFI, Inheritance Tax and SCI Structuring

French Real Estate for Non-Residents: IFI, Inheritance Tax and SCI Structuring

Full analysis of IFI, inheritance tax and tax residence risks for non-residents acquiring French real estate, with practical SCI structuring recommendations.
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