International
An executive who moves abroad exports not only products but also a tax status, an applicable treaty and sometimes a de facto residence for their company.
French law never fades away completely, and local law does not wait for it before applying.
We structure these projects, subsidiary, holding company, joint venture, with a network of local correspondents in the jurisdictions where our clients set up, and one conviction: the structure that protects best is the one designed for exit from the moment of entry.
Our role is to hold both ends at once: what French law requires of the project, what local law requires of the executive, so that no one else has to discover the point of friction between the two.
Your experience
An expatriation, setting up a subsidiary, an operational presence: each project requires French law and a local law to be reconciled, without anyone warning of the exact point where the two contradict each other.
The project always raises a twofold tax question that is rarely discovered all at once: that of the company (transfer pricing, permanent establishment, applicable treaty) and that of the executive moving abroad (tax residence, exit tax).
Our expertise
We structure the vehicle that any presence abroad requires (subsidiary, holding company, joint venture), planning the exit and governance from the outset, not afterwards.
We follow these matters from the initial structuring through to assistance in the event of a tax audit, the most frequently neglected issue in an international project because it never arises when expected.
We assess the permanent establishment risk before a foreign tax authority does it for you, and we build into each structure a suitable dispute resolution clause: international arbitration rather than local courts, where the balance of power warrants it. On the human resources side, we secure the posting and expatriation of employees with regard to the applicable social security regimes, a frequent blind spot in international projects.
The international mobility of executives and family groups is no longer a lifestyle choice but a decision reassessed with every Finance Act. Incentive schemes are tightening in some host countries while multiplying elsewhere. And the automatic exchange of tax information now makes visible what a poorly prepared expatriation thought it could keep quiet.
