International corporate tax
Setting up abroad, withholding taxes and tax audits. Securing the tax position of groups that grow beyond borders.
Supporting companies that cross borders
Growing internationally means taking on complex tax challenges.
We advise companies on structuring and securing their cross-border operations, taking into account tax treaties, local regulations and developments in international tax law.
Whether it involves investments abroad, international operations, intragroup flows or preventing the risk of double taxation, we build tailored solutions that combine effectiveness, legal certainty and compliance with international standards.
You are growing your business internationally
Investment abroad, setting up a subsidiary, a new location, financing the group’s entities, reorganization.
- Investments and operations abroad: structuring upfront
- Intragroup financing: capitalization, debt, agreements
- Permanent establishment risk in France or abroad
- Transfer of functions, assets or activities between entities
Your intragroup flows must be secured
Transactions between related companies, royalties, cost re-invoicing, intragroup services and financing.
- Intragroup flow pricing at the arm’s length principle
- Documentation: Master File, Local File, functional analyses
- Benchmarking studies and arm’s length ranges
- Withholding taxes and application of tax treaties
- Preventing and eliminating double taxation
You are facing a tax audit
An audit of your international flows or your withholding taxes, through to litigation if necessary.
- Review of the regularity of the procedure and the deadlines
- Responses to the tax authorities and technical arguments
- Administrative appeals and defense of your position
- Securing your policies for the future
A different situation? A first conversation lets us map out what is at stake.
Reading the group as a single system
International taxation is not handled flow by flow.
Permanent establishment, withholding taxes and intragroup financing are not separate topics. A decision made in one country has consequences in another. Looking at them in isolation leaves blind spots that come at a cost during an audit.
We take up the group’s value chain and its intragroup flows, then read them against the OECD principles and the applicable tax treaties. Every position is documented, with functional and economic analyses, benchmarks, Master and Local File, so that it is defensible before the tax authorities, not merely presentable.
An international matter involves several jurisdictions. We coordinate the analyses with local tax advisors in the countries concerned, so that the positions taken stay consistent across the group, from one country to another and over time.
Your questions on international corporate tax
The questions that come up most often among groups expanding internationally.
01 When should you consult on your company’s international taxation? +
There are four decisive moments. Before setting up abroad or creating a subsidiary, to structure upfront. When defining or reviewing your intragroup flows, to secure your intragroup flows. As soon as you receive an audit notice, to secure the procedure. And during a reorganization, which often shifts functions and risks without the tax consequences being measured. The earlier we step in, the wider your room for decision.
A first conversation to map out your international tax challenges.
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