Fewer than 183 days in France = no French tax residency?
Think again.
In the May 2025 print edition of Trusts & Estates, our lawyers Michel Dayanithi and Margaux Niclout debunk one of the most enduring myths in cross-border tax planning.
The idea that you can safely avoid French tax residency by spending fewer than 183 days in France is not only incorrect, it’s dangerously misleading.
With the 2025 French Finance Bill now extending the statute of limitations to 10 years in cases of “false domiciliation,” misunderstanding residency rules isn’t just a technicality: it’s a risk with serious consequences.
Many thanks to Trusts & Estates for the opportunity to contribute to this issue.
➡️ Read the full piece here
Authors
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Michel founded Syntaxe in January 2024
Admission to the Bar
2017
Education
> London Business School
— Masters in Management
> Montpellier Law School
— Masters in Corporate Law and Tax Law
— Certificate of Specialization in Tax Law
— Certificate of Specialization in Economic Law
— Diploma in Criminology and Criminal Sciences
— Diploma in Wealth Management
Languages
English · French
Contact
Margaux joined Syntaxe in September 2024
Admission to the Bar
2024
Education
> Paris II Panthéon-Assas University
— Master’s Degree in Personal and Professional Wealth Management
— Master’s Degree in Business Law
Languages
English · French
Contact
