RONGEAT AVOCAT

Notification assistance in particular the year of departure or arrival in France

Determination of tax residence and resolution of residential conflicts

Transfer of tax residence outside France : year of departure, reporting obligations, exit from latent income and capital gains, savings contracts

Exit tax (art. CGI 167 bis): determination of the base, automatic or optional stay of payment, provision of guarantees, annual monitoring obligations, adjustment and refund, articulation with a pre-existing tax deferral (transfer)

Taxpayers (article 155 B of the CGI): eligibility, tax allowance, exemption from remuneration for foreign activity

Expatriation and detachment : expatriation contracts, exemption for employees posted abroad (article 81 A of the CGI)

Cross-border teleworking : distribution of the right to impose, bilateral agreements applicable to frontier workers, fiscal/social security link, risks to the employer

Drivers and mobile frames Social mandates exercised in several states, count of days of presence, residence of leaders

Taxation of income from French sources, minimum tax rate and average rate clause

Real estate gains of non-residents : determination, exemptions, certified tax representative

Acquisition of real estate in France by a non-resident : financing, detention structure, declaratory consequences

3 % annual tax on the market value of immovables held by legal entities (article 990 D et seq. of the CGI): reporting obligations and exemptions

Permanent establishment : risk analysis and prevention, effects of teleworking of employees abroad, allocation of profits, permanent establishment in respect of VAT

Implementation a foreign group in France and international development of a French group: choice between subsidiary, branch and representative office

Transfer pricing Transfer pricing policy, mandatory documentation and local file, 2257-SD declaration, friendly procedures and advance pricing agreements

International donations and successions (art. CGI 750 ter): territoriality of transfer rights free of charge, inheritance tax treaties, imputation of taxes paid abroad

Financial accounts and digital assets held abroad Reporting obligations, statute of limitations, fines and regularization

Cross-border real estate detention : acquisition of property abroad by a French resident, acquisition of French property by a non-resident, articulation of capital gains schemes

Anticipation of succession of international families : articulation of the European succession regulation, matrimonial regime and taxation