Cabinet tax lawyer Paris
Law firm · Paris 8th · Since 2011

French international tax lawyer — exit tax, Dubai, non-residents

The Office of Me Jonathan Sémon advises individuals, expatriates, executives and businesses facing tax situations involving multiple countries — in preventive counsel and crisis management.

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2011Firm established
120+Tax conventions
9Areas of expertise
Paris 8th7 rue Chateaubriand
⚖️Paris BarRegistered lawyer
🏅15+ yearsof experience
🌍120+ tax treatiesmastered
⏱️Response within 24hto all inquiries
💻Video availableworldwide
Tax law office Paris 8th
The firm

A firm dedicated to
complex tax situations

The Office of Me Jonathan Sémon is a Paris law firm exclusively dedicated to international tax law. It advises individuals, expatriates, executives and businesses facing tax situations involving multiple countries: departure or return to France, tax residence abroad, undeclared foreign accounts, international tax audits, tax treaty application.

international tax law requires mastering French tax law, bilateral tax conventions, tax residence rules under article 4 B of the CGI, and declaration requirements specific to cross-border situations. An analytical error at this stage can have lasting tax consequences.

Applicable laws

Art. 4 B CGIArt. 167 bis CGIArt. 155 B CGIArt. 1649 A CGIArt. 1649 AB CGIArt. L. 12 LPFArt. L. 57 LPF

Why a tax lawyer rather than an accountant?

A tax lawyer intervenes when the situation involves legal uncertainty, risk of assessment, or the need to argue before the tax authorities. They can represent their client before tax authorities and courts — a competence that accountants do not have.

Tax adviceTax advice
ExecutivesExecutives
internationalinternational
Paris 8thParis 8th
Situations handled

The most
frequently handled issues

The firm handles international tax situations comprehensively — both preventively and in crisis management.

expatriation tax residence
01
expatriation & tax residence

Fiscal expatriation refers to transferring tax residence outside France under article 4 B of the CGI. This transfer ends worldwide income taxation and may trigger exit tax (article 167 bis CGI).

Art. 4 B CGI · Art. 167 bis CGI
Return to France repatriation
02
Return to France — Expatriate tax incentive

The expatriate tax incentive regime (article 155 B of the CGI) provides temporary tax exemptions for individuals moving to France on certain compensation and foreign-source income. This regime applies under conditions and for a limited period.

Art. 155 B CGI
Undeclared foreign accounts
03
Undeclared foreign accounts

French tax residents are required to declare accounts opened, held, used or closed abroad (article 1649 A of the CGI). Failure to do so exposes them to fines of €1,500 to €10,000 per account per year, plus back taxes.

Art. 1649 A · 1649 AB CGI
Tax audit redressement
04
Tax audit

A tax audit may take the form of an accounting verification or examination of personal tax situation (ESFP, article L. 12 LPF). The firm intervenes from receipt of notice through litigation if necessary.

Art. L. 12 LPF · Art. L. 57 LPF
Cross-border tax compliance
05
Cross-border tax compliance

Cross-border tax compliance requires coordinating reporting obligations across multiple jurisdictions to ensure full adherence to applicable domestic and treaty rules.

Bilateral tax treaties · CGI
international successions
06
international successions

An international succession is a succession with a foreign element: property located abroad, deceased or heir not resident in France. Without a bilateral succession convention, domestic law rules can lead to double taxation.

CGI · Private international law
Areas of practice

Nine areas of expertise
at your service

Each area is handled with the same analytical rigor, regardless of situation complexity.

International Tax
international tax
Bilateral conventions, double taxation, tax residence, permanent establishment.
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Tax treaties & double taxation
Tax treaties & double taxation
Treaty analysis, double taxation relief, cross-border compliance, permanent establishment.
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Individual Tax
Individual Tax
Income tax, capital gains, foreign income, non-resident obligations.
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Tax audit
Tax audit
ESFP, accounting verification, notice of reassessment, litigation.
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Undeclared accounts
Undeclared accounts
Regularization of foreign accounts and structures — art. 1649 A CGI.
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Tax obligations for non-residents
Tax obligations for non-residents
Tax treaty application, elimination of double taxation, cross-border compliance.
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E-commerce
E-commerce
Digital VAT, digital permanent establishment, platform taxation.
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Tax litigation
Tax litigation
Tax disputes, administrative proceedings, tribunal representation.
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Tax treaties
Tax treaties
Bilateral conventions, double taxation, treaty disputes.
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Cabinet lawyer Paris

« Every case begins with a thorough analysis of the situation — not the application of a pre-established template. »

Me Jonathan Sémon — International Tax Lawyer · Paris

Our Method

An Approach Built on
Complete Analysis

Each case is handled from start to finish by Me Sémon — from initial analysis to defence before the courts.

01
Preliminary Analysis

Identification of real issues, tax risks and applicable laws — French domestic law, bilateral conventions, cross-border reporting obligations.

02
Strategy Definition

Building a strategy consistent with the client's personal, professional and business objectives, strictly complying with applicable laws.

03
Implementation & representation

Drafting of documents and memoranda, correspondence with the tax authority. Representation before tax authorities and courts if proceedings are initiated.

04
Long-term Follow-up

International tax situations change with legislation and the client's life. The firm ensures follow-up to anticipate any impactful changes.

Me Jonathan Sémon — International Tax Lawyer Paris
Me Jonathan Sémon
International Tax Lawyer · Paris Bar
Contact the firm

When facing an international tax issue, the timing of consultation is rarely neutral.

📍 7 rue Chateaubriand, 75008 Paris
📞 01 87 44 29 51
📞 07 56 81 81 66
contact@avocat-fiscal-semon.com
Me Jonathan Sémon

Tax Lawyer
since 2011

Me Jonathan Sémon founded his Paris practice in 2011, after five years of practice in two French firms with international scope specializing in corporate and individual taxation.

The firm SELAS Jonathan Sémon is exclusively dedicated to international taxation. Each case is handled by Me Sémon himself, from the first consultation through to defence before the courts.

Career
2011
Founded SELAS Jonathan Sémon
Paris law office dedicated to international taxation — 7 rue Chateaubriand, 75008 Paris.
2006

2011
International Law Firms
Five years of practice in two French law firms specializing in business and individual taxation with international dimension.
Bar
Lawyer at the Paris Bar
Registered at the Paris Bar. SELAS Jonathan Sémon, international tax law firm.
Droit fiscal international
Booking

Book your
consultation

The first consultation allows you to present your situation and obtain a complete analysis of your tax issues. Two formats available.

💻
Video Consultation
360 €
1 hour · Video Consultation
Ideal for clients residing abroad or outside Paris. Same quality advice, without geographical constraints.
AvailabilityMonday — Friday · 9am — 6:30pm
Time zone adaptation available upon requestHow it worksGoogle Meet link sent 24 hours before
Secure and confidentialBefore the ConsultationSend your questions and documents by email.
Book Video Call
🏛️
Office consultation
450 €
1 hour · In-person
Meet Me Jonathan Sémon at 7 rue Chateaubriand. Recommended format for complex cases requiring document review.
Address7 rue Chateaubriand, 75008 Paris
George V Metro (Line 1)ScheduleMonday — Friday · 9am — 6:30pmBefore the ConsultationSend your questions by email to optimize consultation time.
Book Office Visit
01
Initial consultation
Complete assessment of your tax situation. Presentation of available options.
02
Action plan
Development of a strategy tailored to your case. Definition of steps and mandatory deadlines.
03
Implementation & follow-up
Long-term support. Representation before the tax authority or courts.
Ongoing tax audit or urgent situation?

The firm intervenes from receipt of the first notice. Each step of an audit procedure has mandatory deadlines.
Contact directly: 01 87 44 29 51 · 07 56 81 81 66

Frequently Asked Questions

What our clients
ask us

An international tax lawyer is a lawyer whose practice centers on taxation of situations involving multiple jurisdictions. They articulate domestic tax law (CGI, LPF, BOFiP administrative doctrine), bilateral tax conventions (OECD model), and cross-border reporting obligations to determine applicable tax treatment. Unlike the generalist tax advisor, they reason simultaneously within multiple legal systems — essential when two tax authorities claim competence over the same income or taxpayer.
In-office consultation at 7 rue Chateaubriand, Paris 8th: 450 euros incl. VAT per hour. Video consultation: 360 euros incl. VAT per hour. A detailed quotation is provided for any mission beyond the initial consultation. Documents and questions may be submitted by email beforehand. For urgent matters (tax audit notice or adjustment proposal), contact directly by phone or email to discuss timing and deadlines, which are mandatory under French tax procedure law (articles L. 57 and L. 192 LPF).
The penalties differ by asset type: Accounts opened, held, used or closed abroad (art. 1649 A CGI, form 3916) incur a fine of €1,500 per account per year, raised to €10,000 where the account is located in a State or territory that has not concluded with France an administrative-assistance convention allowing access to banking information (art. 1736 IV CGI). Capitalisation contracts or investments of a similar nature subscribed outside France (art. 1649 AA CGI, form 3916-bis) are subject to a separate penalty regime. Trusts (art. 1649 AB CGI, forms TRUST) incur a €20,000 penalty (art. 1736 IV bis CGI). All fines are added to back taxes increased by 40% (manquement délibéré, art. 1729 a) or 80% (manœuvres frauduleuses, art. 1729 c). The assessment period may be extended to ten years (LPF, art. L. 169 § 5) where foreign-asset reporting obligations have not been fulfilled — this 10-year extension being subject, for foreign bank accounts (art. 1649 A), to the aggregate credit balance having exceeded EUR 50,000 at any time during the year, and being limited to the income relating to the unfulfilled reporting obligations.
Art. 1649 A CGI Art. 1649 AA CGI Art. 1649 AB CGI Art. 1736 IV CGI Art. 1736 IV bis CGI Art. L. 169 LPF
Exit tax, codified in article 167 bis CGI, imposes unrealized gains on equities, securities, and rights when transferring tax residence outside France. It applies to taxpayers who were French tax residents for at least six of the ten years preceding the transfer and hold rights, shares, securities or qualifying interests representing at least 50% of a company's profits, or qualifying rights, shares and securities whose aggregate value exceeds EUR 800,000. A payment deferral applies automatically (without any prior request, tax representative or guarantee) where the destination is a Member State of the EU, or any other State or territory that has concluded with France both a mutual administrative assistance convention and a mutual recovery assistance convention of comparable scope to Directive 2010/24/EU, and is not listed as a non-cooperative jurisdiction (CGI, art. 167 bis IV; art. 238-0 A). For other destinations, deferral may be granted only on election (CGI, art. 167 bis V) subject to three cumulative conditions. Relief (dégrèvement) may occur after two years where the aggregate value of securities subject to exit tax is not exceeding EUR 2,570,000, or after five years where this threshold is met or exceeded, provided no event triggers the end of the deferral.
Art. 167 bis CGI BOI-RPPM-PVBMI-50-10
Double taxation refers to imposition of tax by two states on the same income or asset. France's bilateral tax conventions employ two mechanisms: exemption with progressive application (foreign income is exempted but retained for effective tax rate calculation) and imputation of a tax credit equal to French tax on foreign-source income. The choice of method depends on applicable convention and income category. Proper application requires combined reading of convention text, domestic law, and administrative guidance (BOI-INT-DG-20-20).
BOI-INT-DG-20-20 OECD Model Art. 23 A/B
Yes. The Firm regularly accompanies clients residing outside France, particularly those in the Gulf region, the UAE, Asia, and North America. Consultations are conducted by video conference with time zone adaptation upon request. Tax consultation and advice before the French tax authority are conducted entirely remotely. Representation in administrative proceedings can be handled remotely following delivery of supporting documentation by email.
The accountant prepares financial statements and files tax returns. The tax lawyer intervenes when the situation contains legal uncertainty, risk of adjustment, or the need to defend a position against the tax authority. Only the tax lawyer has standing to represent a client before administrative courts — trial court, appellate court, and supreme administrative court. The lawyer has general and permanent professional privilege (secret professionnel), subject to the limitations prescribed by law, including anti-money laundering vigilance obligations (LCB-FT).
As a matter of practical recommendation, an anticipation period of six months before planned departure is advisable. This timeframe is necessary to evaluate exit tax exposure (article 167 bis CGI), prepare transfer declarations (form 2074-ETD), structure the residency transition according to applicable tax treaties, and identify French-source income remaining taxable after departure — including rental income, capital gains on real estate, and pensions (article 164 B CGI). When your assets include significant holdings or interposed structures, a twelve-month lead time is preferable.
Contact Us

Let's discuss your
tax situation

For any consultation or preliminary information request, contact us directly.

Paris 8th
Address
7 rue Chateaubriand
75008 Paris · George V Metro (Line 1)
Phone
Email
Ongoing Tax Audit ?

The firm intervenes upon receipt of the first notice. Procedural deadlines are imperative — do not delay consulting.