INTERNATIONAL TAX
International tax lawyers for expats, business owners and groups
Tax is not a consequence of the project. It often determines its structure.
One person can live in the UAE, earn income in France, own a company in Canada and invest in several jurisdictions.
Expats Law Firm advises individuals, entrepreneurs, SMEs and groups on the tax consequences of their mobility and international operations.
The France–Canada and France–UAE tax treaties can become central in the matters concerned.
TAX RESIDENCY & EXIT TAX
Physically leaving is not always enough to move your tax residency
Tax residency is assessed on the basis of the taxpayer's actual situation, the domestic law of the countries concerned and, where two countries claim residency, the applicable tax treaty.
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determining tax residency;
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residency conflicts;
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tax treaties;
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transferring residency out of France;
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exit tax;
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ongoing exit tax obligations;
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shareholdings and companies held;
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income retained in the home country;
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returning to France or moving abroad again.
The France–Canada and France–UAE tax treaties can become central in the matters concerned.
NON-RESIDENTS & INTERNATIONAL INCOME
A non-resident may retain:
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We determine the source of the income, each country's taxing rights and the treaty mechanisms that make it possible to avoid or correct double taxation.
ENTREPRENEURS & BUSINESS OWNERS
A business owner's personal tax and that of their companies can become inseparable
An expatriate business owner may continue to make decisions for a company located in their former country of residence.
An entrepreneur may hold several entities and run their business from a jurisdiction other than the one where those entities are incorporated.
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remuneration;
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dividends;
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functions actually performed;
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place of decision-making;
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effective management;
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relationships between the business owner and the companies;
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permanent establishment;
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tax consequences of holding a foreign company.
SMEs & INTERNATIONAL GROUPS
An international expansion must be clear from a tax perspective
When a business enters a new jurisdiction, the question is not only where to incorporate the company.
It is necessary to understand:
where the business is actually carried on;
what substance exists;
where the teams work;
what flows take place;
how functions should be remunerated;
whether a permanent establishment may arise.
For groups, our practice also covers:
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transfer pricing;
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intragroup services;
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management fees;
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recharges;
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distributions;
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financial flows;
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restructuring;
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consistency between functions, contracts and invoicing.
AUDIT • REGULARISATION • DISPUTES
When international tax becomes contentious
A change of country can lead to disagreements over residency, the source of income, the characterisation of a transaction or reporting obligations.
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At that point, the challenge is no longer only to structure the future: the past must also be dealt with.
FRANCE • CANADA • UNITED ARAB EMIRATES
France
Residency and non-residency, exit tax, French-source income, capital gains, shareholdings, tax audits and regularisations.
Canada & Quebec
Tax residency, leaving or arriving in Canada, federal and Quebec tax, tax treaties, CRA, Revenu Québec, foreign income and assets.
United Arab Emirates
Tax residency, Corporate Tax, flows with foreign companies, taxation of UAE structures and interactions with the home country.
FREQUENTLY ASKED QUESTIONS
