Expatriation
Support for the departure: social and tax status during expatriation, expatriate or secondee employment contract, articulation with French social security.
→ Executives · Sub-expertise
An executive's international mobility — expatriation, impatriation, change of tax residence — raises complex tax, social and asset issues: exit tax, tax treaties, spouse status, international remuneration. We support these transitions in connection with your tax adviser and the relevant foreign advisers.
→ What we cover
Support for the departure: social and tax status during expatriation, expatriate or secondee employment contract, articulation with French social security.
Favourable tax regime for inbound assignees (impatriés) under conditions, structuring of remuneration, spouse status, children's schooling, social security.
Review of the residence criteria (household, main place of stay, professional activity, centre of economic interests), planning of the change.
Application of the exit tax on latent capital gains in the event of a transfer outside France above certain thresholds, deferral mechanisms, post-departure monitoring.
Application of bilateral tax treaties to avoid double taxation, articulation with local regimes, overall planning.
Management of assets in a mobility context: matrimonial regime, international succession, choice of the applicable law, articulation of civil and tax conventions.
→ Our approach
01
Analysis of the current situation (residence, activity, assets, family) and the mobility project (duration, host country, functions performed).
02
Definition of an overall strategy (tax, social, asset), in connection with your tax adviser and the relevant foreign advisers.
03
Preparation of the deeds (contract, declarations, transfers), formalisation of the change, administrative support (social security, tax authorities, civil status).
04
Monitoring of reporting obligations, anticipation of a possible return, management of family and asset developments during the mobility.
→ Who we help
Support for a French executive relocating to the United States: social status, taxation, exit tax, structuring of remuneration, management of French assets.
Return to France after several years of expatriation: application of the inbound-assignee tax regime, optimisation of remuneration, asset structuring.
Sale of a French business after a change of tax residence: articulation with the exit tax, application of the tax treaty, overall optimisation.
Mobility of a senior executive between European subsidiaries of the same group: articulation of the contracts, social security, taxation, management of real estate assets.
→ Q&A
Several alternative criteria under French law: household or main place of stay in France, professional activity carried out in France on a principal basis, centre of economic interests in France. A tax treaty may modulate these criteria. A case-by-case analysis is essential.
A taxation of latent capital gains on shares held at the time of the transfer of tax residence outside France, applicable above certain thresholds. A payment deferral may be obtained under conditions, and the tax may be relieved under certain circumstances.
No, several strict conditions: not having been a French tax resident for several years before arrival, taking up specific functions in a French company, meeting remuneration thresholds. The regime offers partial tax exemptions on certain remuneration components.
Through the application of bilateral tax treaties: they allocate the right to tax between the two States (residence and source) and provide for elimination mechanisms (exemption or tax credit). A precise analysis of the applicable treaties is essential.
→ Go further
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