International representation is in our DNA
International work is part of our DNA. We developped a particular expertise with German speeking countries. But our expertise is much larger and may cover all jurisdictions.
Indeed, we always deal with the case from the perspective of French law, but with a particular outlook, since it incorporates the legislation of one or more other States.
On a daily basis, we deal with issues of territoriality in terms of taxation of results, income and assets, as well as value added tax (VAT).
We deal with the taxation of private individuals’ income, but also of their assets or in the event of inheritance or donation.
Should the beneficiary or heir reside in France or the property transferred be located in France, the inheritance or gift will be taxable in France.
For companies, the international dimension is even more pressing because, even if they are not established in another country, any company of a given size will sell goods or offer services beyond its borders. This raises the issue of tax territoriality.
As soon as your international activity expands, the issue of the existence of a permanent establishment in the State of activity will inevitably arise and will even be decisive for the taxation of profits in that State, but also of any employees seconded to that State.
Finally, in the case of international groups, questions will regularly arise as to the allocation of the tax base and therefore the setting of transfer prices.
EXAMPLES OF INTERVENTIONS
Avoidance of double taxation in corporate, income or wealth-tax matters
Structuring international activities in order to reduce the tax burden, within the frameworks set by national and international legislations
Structuring of foreign investments in France
Reorganization of foreign groups’ French subsidiaries
Analysis of flows and services with regard to VAT Territoriality rules
Assistance in VAT refunds to foreign taxable persons
Management of transfer pricing issues both in terms of pricing and preparation of the required documentation
Assistance in tax audits and litigation, either through traditional channels (administrative appeals and before national courts) or through specific procedures for the prevention of double taxation (amicable procedures and arbitration procedures) provided for in bilateral tax treaties and in some international standards
Procedures for the refund of withholding taxes and tax flows optimization
Assistance to French groups in their investments abroad in collaboration with local colleagues
Planning inheritance transfers to minimize the impact of taxes, which are often higher in France than abroad
Counseling of impatriates or expatriates
While international representation is everyday practice at ITRS Avocat, Franco-German relations or, more generally, relations with German-speaking countries have pride of place.
Indeed, this dual Franco-German identity is one of ITRS Avocat’s foundations.
Each of our members is fluent in French and German and can therefore conduct business in their client’s mother tongue.
GENUINE KNOWLEDGE OF THE GERMAN-SPEAKING WORLD
In addition to language fluency, our knowledge of the German-speaking world ensures greater awareness of your specific problems or needs, and therefore greater responsiveness to your expectations.
Our experience acquired in Germany, on the ground or through exchanges with our clients and foreign colleagues, means we have gained a thorough understanding of the German tax system in order to better direct our advice.
In the context of consultations covering both jurisdictions or to accompany a French operator abroad, we rely on our worldwide contacts network and particularly in Germany, German Switzerland or Austria.
EXAMPLES OF OUR WORK
Recurrent assistance to numerous German groups’ subsidiaries and branches, or more widely from the German-speaking world (Germany, Switzerland, Austria, etc.)
Assistance to German residents investing or operating in France
Settlement of double taxation issues at both the declaratory and contentious stages
Settlement of international succession cases.