#International Tax Lawyer in Paris

An international tax lawyer secures your position in situations that involve more than one country’s tax laws: leaving or returning to France, foreign-source income, setting up outside France, intra-group flows. Hashtag Avocats advises executives, internationally mobile individuals and companies in Paris, from upfront advice through to litigation. Every situation is different and is analysed in light of French law and the applicable tax treaties.

When should you use an international tax lawyer?

The sensible approach is to seek advice before the transaction, not after it. Typical situations: an executive moving abroad or to France, receipt of foreign income, holding accounts or companies outside France, setting up a subsidiary or branch abroad, invoicing between companies in the same group. In each case, a mistake in classification can lead to double taxation or a tax reassessment. The lawyer identifies the applicable rules, quantifies the consequences of the available options and secures your tax returns.

Tax residence and double taxation

How is French tax residence determined?

Article 4 B of the French Tax Code (Code général des impôts, CGI) sets three alternative criteria for tax domicile in France: your home or principal place of stay, carrying on a professional activity in France other than on an ancillary basis, or the centre of your economic interests. A single criterion is enough. A taxpayer domiciled in France is taxable on their worldwide income; a non-resident is taxable only on French-source income. The residence question is therefore the starting point of any international tax analysis.

The role of bilateral tax treaties

When two States both claim the same person as a resident, the tax treaty between them resolves the conflict and allocates the right to tax each category of income. The official list of treaties signed by France is published on impots.gouv.fr. Article 4 B of the Tax Code also rules out French tax domicile where, under a treaty, the person is not regarded as resident in France. Double taxation is then eliminated, depending on the treaty, by a tax credit equal to the foreign tax or to the French tax, or by an exemption with progression (effective rate). A close reading of the applicable treaty is essential: each text has its own features.

Internationally mobile executives: leaving and returning to France

French exit tax: who is affected?

Moving your tax domicile out of France can trigger the exit tax under Article 167 bis of the Tax Code (in force on 6 July 2026). It applies to taxpayers who were domiciled in France for at least six of the ten years before departure, where their shares represent at least 50% of a company’s profits or exceed €800,000 in total value. The tax is charged on unrealised capital gains. A deferral of payment applies automatically on departure to a European Union State or to a cooperative State bound to France by the required assistance agreements; elsewhere, it requires guarantees and the appointment of a representative. The tax is discharged if the shares are kept for two years after departure, a period extended to five years where their value exceeds €2.57 million.

Inbound and outbound expatriates

Returning or moving to France also needs preparation: the inbound expatriate (impatriés) regime, treatment of income received before arrival, handling of foreign share plans, and foreign accounts to be declared every year. Conversely, an outbound expatriate must organise the switch of residence, what happens to their French assets and their remaining filing obligations. These questions overlap with those we deal with on our personal tax page. Undeclared foreign accounts call for a specific tax regularisation process.

Since 2026, two paths can be distinguished. The first concerns people who actually move their tax residence out of France: the criteria of Article 4 B of the Tax Code, the exit tax under Article 167 bis, the tax returns for the year of departure and what happens to assets kept in France. The second concerns those who stay and plan the transfer of their wealth in light of the 2026 Finance Act. The firm covers these two paths on dedicated pages: leaving France and moving your tax residence, and protecting your wealth before 2027 (in French).

Companies: permanent establishment, transfer pricing, intra-group flows

For a company, the first question is whether there is a permanent establishment: a presence abroad (premises, an agent, a construction site) can create a taxable base there, as defined by the applicable treaty. The second is transfer pricing. Article 57 of the Tax Code allows the tax authorities to add back to French taxable profit any profits indirectly transferred to related companies located outside France, by increasing or reducing prices. The dependence condition does not apply to transfers to territories with a privileged tax regime or non-cooperative territories.

The guiding principle is the arm’s length principle: intra-group transactions must be priced as between independent companies. Pricing policy, documentation, withholding taxes on outbound flows: we structure these matters with our team dedicated to transfer pricing.

Tax audits and disputes in international tax

International cases are among the priority targets of tax audits: disputed residence, undeclared permanent establishment, transfer pricing, foreign accounts and trusts. The time limit for reassessment can be extended to ten years in some of these cases. The defence relies on specific tools: arguing the treaty classification, the mutual agreement procedure between States to eliminate double taxation, and litigation before the tax courts. Our team of tax lawyers handles this defence from start to finish, working with foreign advisers when the case requires it.

Leaving France, exit tax and protecting your wealth before 2027

Moving your tax domicile out of France triggers the exit tax under Article 167 bis of the Tax Code where the shares held represent at least 50% of a company’s profits or exceed €800,000 in total value. Payment can be deferred: automatically on departure to a European Union Member State, on request and subject to guarantees elsewhere. We devote a dedicated page to these questions: tax expatriation lawyer, supplemented by articles on tax residence, departure formalities and non-resident status.

The ongoing budget debates are also prompting many taxpayers to reorganise their wealth in anticipation of rules that do not yet exist. The 2026 Finance Act kept the real estate wealth tax (IFI) and created a 20% tax on certain assets of personal holding companies; the minimum wealth tax and the tax on unproductive wealth were not adopted. Our page on protecting your wealth before 2027 (in French) sets out, measure by measure, what is in force, what is under discussion and what belongs to an election manifesto.

FAQ

How can you avoid double taxation?

By correctly applying the tax treaty between France and the other State: it designates which State may tax each type of income and provides a mechanism to eliminate double taxation, most often a tax credit. Without a treaty, French domestic law offers more limited remedies. The analysis is carried out treaty by treaty.

What is the French exit tax and who has to pay it?

It is the tax on unrealised capital gains on shares when your tax domicile is moved out of France (Article 167 bis of the CGI). It targets taxpayers domiciled in France for six of the last ten years whose shares represent at least 50% of a company’s profits or exceed €800,000 in total value. A deferral of payment and a discharge after two years, extended to five years above €2.57 million, limit its effect when their conditions are met.

How do you determine your tax residence?

First, under the French criteria of Article 4 B of the CGI: home or principal place of stay, professional activity other than on an ancillary basis, centre of economic interests. Then, if another State also considers you a resident, the bilateral treaty settles the matter using its own successive tie-breaker criteria. A documented analysis helps anticipate these residence conflicts.

What is a permanent establishment?

It is a fixed place of business, or in some cases a dependent agent, through which a company carries on its business in another State. Once it is recognised, the profits attributable to it are taxable in that State. The exact definition depends on the applicable tax treaty.

When is transfer pricing documentation mandatory?

Large companies must keep full documentation available for the tax authorities; the exact thresholds depend on rules that are amended regularly. Even below the thresholds, a company must be able to justify its intra-group prices in an audit based on Article 57 of the CGI. Proportionate documentation remains the most effective protection.

Official sources

• Article 4 B of the French Tax Code (Code général des impôts), criteria for tax domicile in France: Légifrance (in French)
• Article 167 bis of the French Tax Code (Code général des impôts), taxation of unrealised capital gains on transfer of domicile out of France (exit tax): Légifrance (in French)
• Article 57 of the French Tax Code (Code général des impôts), indirect transfers of profits between dependent companies (transfer pricing): Légifrance (in French)
• Official list of international tax treaties signed by France: impots.gouv.fr (in French)

Law as in force on 6 July 2026. This content provides general information and does not constitute legal advice. Every situation is different: contact our team to have your cross-border situation reviewed.