International Tax Paris
Area of Expertise

International Taxation

The Firm

Complete Expertise in
International Tax Law

International taxation requires the simultaneous mastery of French domestic tax law, bilateral tax treaties, and European Union law. The internationalization of activities and assets creates complex issues when a resident of one state conducts operations in another state — or when a non-resident operates in France.

The Firm of Me Jonathan Sémon is exclusively dedicated to these situations. Me Sémon advises both businesses facing international tax challenges and individuals whose tax situation extends beyond French borders.

1. International Businesses

Cross-border tax compliance. Coordination of reporting obligations and tax positions across multiple jurisdictions — analysis of applicable treaty provisions, identification of compliance requirements, and proactive management of declaration risks.

Bilateral tax treaties. Expert analysis of treaties concluded by France to understand their impact on operations: avoidance of double taxation, allocation of taxing rights between states, anti-abuse provisions.

International subsidiaries and holdings. Advice on creation and management of foreign subsidiaries and holding companies—analysis of tax treaty implications and optimization of cross-border ownership structures.

International real estate investments. Tax treatment of real estate investments in France and abroad—optimization strategies for each relevant jurisdiction and mitigation of withholding tax obligations.

Tax management for expatriates. Adapted planning solutions for internationally mobile employees—tax compliance, compensation optimization, dual residence.

2. Individuals

Tax residence. Tax residence is defined in article 4 B of the CGI. Its determination is the first issue to address when leaving or returning to France, or when living in multiple countries.

Expatriates and impatriates. Management of expatriation tax implications: double taxation, exit tax (art. 167 bis CGI), impatriate regime (art. 155 B CGI), residual reporting obligations in France.

Tax treaties. Thorough analysis of bilateral agreements applicable to your situation—their interpretation is often disputed and requires specific expertise.

International successions and gifts. Tax management of cross-border transmission in estates and gift planning—France has concluded only a limited number of succession treaties.

Foreign real estate investments. Advice on French and international markets, notably Dubai and the United Arab Emirates.

Applicable Legal References:

Art. 4 B CGIArt. 167 bis CGIArt. 155 B CGIArt. 57 CGIArt. 209 B CGIApplicable bilateral tax treaty
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Related Pages
→ Tax Residence → Tax Treaty Matters → Undeclared accounts
Cases Handled

What the Firm
Handles Concretely

01
Double Taxation
Double taxation refers to the situation where the same income is taxed by two states simultaneously. France has concluded more than 120 bilateral treaties to eliminate it—through exemption or credit mechanisms.
02
Conflicting Tax Residence
When two states simultaneously claim a taxpayer's tax residence, the tie-breaker rules of the applicable treaty apply. Art. 4 B CGI
03
Cross-border Tax Disputes
International tax adjustments and disputes with tax authorities require expert analysis of cross-border documentation, intercompany transaction records, and tax audit defense under French and treaty law.
04
Permanent Establishment
The concept of permanent establishment determines if a foreign company is taxable in France. Its analysis clarifies resulting reporting and tax obligations.
05
Exit Tax and Departure from France
Exit tax (art. 167 bis CGI) taxes unrealized gains on certain securities when a taxpayer transfers their tax residence out of France, if they have resided there for at least 6 of the previous 10 years.
06
Impatriate Regime
Individuals relocating to France can benefit from temporary tax exemptions on certain compensation elements and foreign-source income. Art. 155 B CGI
Resources

Related articles

Frequently Asked Questions

Frequently Asked Questions

An international tax lawyer is a lawyer whose practice focuses on the tax rules applicable to situations involving multiple countries. They master French tax law, bilateral tax treaties, and cross-border reporting obligations. They advise and represent individuals as well as businesses whose tax situation exceeds the national framework.
France taxes French-source income of non-residents under articles 164 B and 197 A of the French Tax Code, with a minimum rate of 20% (30% for certain income). Bilateral tax treaties can reduce or eliminate this taxation based on your country of residence. Specific analysis of applicable treaties and the nature of income is necessary to optimize your tax situation.
A bilateral tax treaty, based on the OECD model, determines how income is allocated and taxed between two countries. It provides for the elimination of double taxation through exemption (article 23 A) or tax credit (article 23 B). The treaty takes precedence over domestic law according to the French Council of State's case law, subject to specific competence conditions.
France has concluded more than 120 bilateral tax treaties. The complete list is available on the DGFiP website (impots.gouv.fr). Interpreting these conventions in your specific situation requires thorough legal analysis.
Reporting obligations vary depending on the asset type:

Foreign accounts: Accounts opened, held, used or closed abroad must be declared (article 1649 A of the French Tax Code) via form 3916. Capitalisation contracts or investments of a similar nature subscribed outside France (article 1649 AA) and digital-asset accounts or wallets opened, held, used or closed with entities established abroad (article 1649 bis C) must be declared via form 3916-bis.

Fiduciary structures (trusts): Trusts are governed by a separate regime (article 1649 AB) and require TRUST1/TRUST2 declarations, not forms 3916/3916-bis.

Exit tax: The departure tax on unrealized gains (article 167 bis) requires an initial 2074-ETD declaration and, where the notice requires it, subsequent 2074-ETS3 or 2074-ETSL tracking; this tracking is not automatically annual for every latent-gain-only situation.

Foreign-source income: Form 2047 reports foreign income taxable in France, with no connection to prior asset declarations.

Failure to comply may trigger specific statutory penalties, which vary depending on the nature of the asset, the applicable reporting obligation, and the circumstances of the omission.
The impatriate regime (art. 155 B CGI) allows individuals who relocate to France after foreign residence to benefit from temporary exemptions on certain compensation elements and foreign-source income. It applies under conditions (taking up a position in France, no French residence in the previous 5 years) and for a limited duration.
Contact Us

Let's discuss your
tax situation

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

Address
7 rue Chateaubriand
75008 Paris · George V Metro (ligne 1)
Phone
01 87 44 29 51 · 07 56 81 81 66
Email
contact@avocat-fiscal-semon.com
Consultation fees

Video consultation : 360 € / heure
Office consultation : 450 € / heure