International

In a French economic context weakened by political instability, complex regulation and uncertain growth prospects, investors and entrepreneurs need to rethink their strategy. In France, mounting tax and regulatory pressure is leading many players to consider alternative solutions to preserve and grow their assets. In this context, looking internationally appears to be an alternative, if not a necessity. Diversifying investments, securing assets and taking advantage of the dynamism of certain markets are all levers for meeting the challenges posed by our economic environment.

STRUCTURING, SECURING AND MANAGING YOUR PROJECTS ABROAD

Internationalising a business or a family’s assets cannot be improvised. Expatriation, setting up a subsidiary, an operational presence, holding assets or wealth structuring: each project requires French law and local law to be carefully reconciled.

Our role is to secure that interaction.

We act as strategic advisers to executives, entrepreneurs and investors wishing to develop a presence abroad while keeping control of their tax, legal and wealth issues in France.

Our added value rests on dual expertise:

  • Command of French law (tax, corporate, private wealth)

  • A network of trusted local partners in the jurisdictions where we operate

We coordinate all the parties involved in order to give our clients a comprehensive, consistent and secure view of their project.

United Arab Emirates

Bali

Switzerland

Areas of expertise

International wealth structuring

We assist our clients in structuring their international assets:

  • Holding real estate assets abroad

  • Structuring international shareholdings

  • Succession planning in an international context

  • Asset protection

Each structure is designed in line with the client’s personal and professional situation.

Optimising and securing international flows

International development involves financial and contractual flows that need to be structured rigorously:

  • Organisation of dividend flows and cash upstreaming

  • Framework for intra-group agreements

  • Analysis of international tax treaties

  • Securing transfer pricing

Our approach prioritises compliance and long-term legal robustness.

Expatriation of the executive

We assist executives in preparing and securing their international mobility:

  • Analysis of tax residence and double taxation risks

  • Anticipating the consequences for income tax, the French real estate wealth tax (IFI) and capital gains

  • Structuring remuneration (dividends, management fees, salaries)

  • Securing the executive’s social protection and legal status

  • Preparing the departure and, where applicable, the return to France

The aim is to avoid any risk of recharacterisation or subsequent litigation.

Setting up a subsidiary or holding company abroad

We assist entrepreneurs who wish to:

  • Open an operating subsidiary abroad

  • Set up an international holding company

  • Structure an export business or a local presence

Our work covers in particular:

  • Choosing the appropriate legal structure

  • Analysis of intra-group flows (invoicing, management fees, dividends)

  • Interaction with French taxation

  • Preventing permanent establishment risks

We work in coordination with our local partners on operational implementation.

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Contact

David Ybert de Fontenelle
Partner

Anthony Roustan
Partner