International tax questions rarely arrive one at a time. A group expanding into Europe faces permanent establishment and withholding tax issues, transfer pricing documentation, treaty allocation of taxing rights — and, almost always, an indirect tax exposure that surfaces first, because VAT is declared monthly rather than annually. An individual moving across a border faces the same layering: residence under domestic law, residence under a treaty, and the exit and trailing taxes that follow the move.
I advise foreign companies, their in-house counsel and their advisers, as well as internationally mobile individuals, on that whole perimeter — as a lawyer, which means the analysis is protected by professional secrecy and can be defended before the administration and the courts by the person who wrote it.
What I handle
- Tax treaty analysis — residence, permanent establishment, allocation of taxing rights over business profits, dividends, interest, royalties and employment income, and relief from double taxation when two administrations both claim the same income.
- Structuring of cross-border flows — inbound investment into France, outbound expansion, intra-group financing and services, withholding tax exposure and the substance those positions require.
- Permanent establishment risk — dependent agents, home-office and remote-work patterns, warehouses and commissionnaire structures, and the corporate tax and VAT consequences that follow a finding of establishment.
- Tax audits and litigation — responses to information requests, proposed reassessments, mutual agreement procedures, and proceedings before the French tax courts.
Where indirect tax fits in
In practice, an international structure is tested on the indirect side first: registration duties, import VAT, place-of-supply questions and reporting obligations reveal a group’s footprint to the administration long before a corporate tax return does. When the exposure is indirect, the starting point is my detailed guide to cross-border VAT compliance for foreign companies; the corporate and treaty analysis then builds on facts that are consistent with what has already been declared.
A Franco-Dutch practice
I hold a doctorate in law and practise in French, English and Dutch, from Paris and Rotterdam. My doctoral research examined the conflict between bilateral tax treaties and the Treaty on the Functioning of the European Union — the exact intersection where most difficult international tax questions sit. Franco-Dutch structures, and more generally situations involving France and another Member State, are the core of the practice.
If you are dealing with a cross-border reassessment, planning an investment into France, or simply unsure which of two countries can tax a given flow, the useful next step is a confidential conversation. Contact the firm — everything you share is covered by professional secrecy.