Services

Individuals & Executives

Tailored advice for personal, professional and private wealth matters.

Tax residence & international mobility

Analysis and management of the French tax consequences of moving to France, leaving France or, more generally, situations involving several countries.

Determination of tax residence in cross-border situations
Analysis of dual-residence situations
Application of international tax treaties
French tax consequences of moving to or leaving France
Cross-border remote working and international mobility
Social taxes and social security issues in an international context

Foreign-source income & non-resident taxation

Determination of the French tax treatment of foreign income and assets, as well as French-source income received by non-residents.

Foreign rental income and real estate capital gains
Foreign dividends, interest and investment income
Foreign-source employment and professional income
Foreign pensions and retirement income
French-source income received by non-residents
Double taxation relief under applicable tax treaties

French impatriate tax regime & international compensation

Advice and tax optimisation in connection with moving to France or pursuing an international career.

French impatriate tax regime: eligibility, implementation and securing the regime
Calculation of the impatriation premium exemption and exemption for foreign workdays
Tax claims to obtain the benefit of the regime for prior open tax years
Tax simulations and optimisation of net disposable income
Salaries, bonuses and variable compensation
Free share awards, stock options, RSUs, BSPCE and employee share plans
Termination payments and deferred compensation in an international context

Tax returns & compliance

Assistance with French tax filing and compliance obligations arising from an international personal or private wealth situation.

Preparation and review of French income tax returns
Reporting and French tax treatment of foreign-source income
Reporting of foreign bank accounts, financial accounts and contracts
Obtaining a French tax identification number
Setting up and adjusting French withholding tax
Withholding tax filings for non-residents
French differential contribution on high incomes (CDHR)
Corrections and voluntary amendments of previous tax returns
French real estate wealth tax (IFI) returns

International private wealth & estate planning

Advice on the French tax consequences of holding, transferring or restructuring international private wealth.

International inheritances
Cross-border gifts
French taxation and reporting of trusts and foreign wealth structures
French real estate wealth tax (IFI)
Exit tax and changes in tax residence
International real estate and financial investments
Crypto-assets held in an international context
Tax analysis relating to real estate and financial assets

Voluntary disclosures, tax audits & disputes

Assistance in dealings with the French tax authorities where an international tax situation requires clarification or regularisation, or is subject to an audit.

Voluntary disclosure and regularisation of international tax situations
Responses to information requests from the French tax authorities
Tax audits involving foreign income or assets, the impatriate tax regime or tax residence
Challenges to French withholding taxes or other French tax assessments
Pre-contentious tax claims
Tax rulings and requests for formal positions from the French tax authorities
Pre-litigation and tax litigation assistance

Employers

Support for businesses and HR teams in managing the French tax and social security aspects of international employee mobility.

Tax compliance & support for internationally mobile employees

Support for employees and employers with French tax obligations arising from an arrival in France, a departure abroad or an international assignment.

Arrival and departure tax briefings
Analysis of the employee’s tax residence
Assessment of eligibility for the French impatriate tax regime
Preparation or review of French income tax returns
Review of payroll applying the impatriate regime or treaty exemptions
Obtaining a French tax identification number (NIF)
Setting up and adjusting French withholding tax
Withholding tax filings for non-resident employees
Assistance with requests or audits from the French tax authorities

Tax strategy & global mobility policies
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Advice to employers on tax arrangements and policies designed to support internationally mobile employees.
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Implementation and securing of the French impatriate tax regime
Advice on tax equalisation and tax protection policies
Review of gross-up arrangements and guaranteed net compensation
Tax treatment of mobility and termination allowances
Pension arrangements in the context of an international career
International employee share plans: free share awards, stock options, RSUs, BSPCE, etc.
Review of global mobility policies and compensation packages

Compensation structuring & complex calculations

Tax simulations and calculations designed to structure international compensation and anticipate its cost for both the employee and the employer.

Net-to-gross and gross-to-net calculations
Net disposable income projections
Employer cost calculations and budget projections
Tax equalisation and tax protection calculations
Gross-up calculations
Allocation of compensation between several countries
Allocation between employment income and other compensation items
Simulations relating to the French impatriate tax regime

Global mobility & social security
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French tax and social security advice on international assignments and cross-border situations encountered by employers.

Advice on international assignments and employee transfers
Secondments, expatriations and local hires
Review and drafting of tax and social security clauses in mobility agreements
Analysis of the applicable social security legislation
Bilateral social security agreements
Cross-border remote working and hybrid working arrangements
Coordination with HR, payroll teams and external providers
Payroll assistance to ensure French tax and social security compliance