Support for business owners with international interestsTax lawyers in Bordeaux, Paris and Hossegor

1- Structuring and holding interests abroad

We assist business owners with the structuring and tax optimisation of their international investments and activities, in particular:

• Analysis of the existing structure (companies, holding companies, permanent establishments);
• Choice and implementation of suitable holding structures (international holding companies, intermediate companies, investment vehicles);
• Review of international tax treaties and prevention of double taxation;
• Securing cross-border financial flows (dividends, interest, royalties);
• Support with the creation or acquisition of companies abroad.

2- International mobility of senior executives and business owners

We support executives through every phase of their international mobility, whether temporary or permanent:

• Analysis of tax residence and the criteria for taxation;
• Tax support when moving abroad or returning to France;
• Anticipating and managing exit tax;
• Taxation of international remuneration (salaries, management fees, stock options, free shares);
• Coordination with local advisers in the countries concerned.

3- International wealth taxation for business owners

Our firm advises on the cross-border wealth issues faced by business owners:

• Structuring and transfer of international wealth;
• Taxation of foreign-source income and capital gains;
• Holding real estate assets abroad;
• International taxation of life insurance and financial investments;
• Succession planning in an international context.

4- Capital transactions and international taxation

We assist executives and shareholders with their strategic transactions with an international dimension:

• Sales of shareholdings or businesses involving cross-border issues;
• Reorganisations of international groups;
• Contributions, mergers and international restructurings;
• Optimising and securing the taxation of capital gains;
• Assistance with fundraising or international private equity transactions.

5- Tax compliance and international risk management

The proliferation of reporting obligations and the intensification of information exchange between States expose executives to heightened tax risks. We advise in particular on:

• Bringing international reporting obligations into compliance (foreign accounts, structures held abroad, trusts);
• Assistance in international tax audits and tax litigation;
• Procedures for regularising international tax situations;
• Preventing risks related to anti-abuse rules (transfer pricing, economic substance, beneficial ownership).