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From Tax Audit to Criminal Liability: Understanding the French Automatic Referral Mechanism

Since the 2018 Anti-Fraud Law, French tax audits can automatically turn into criminal cases. When total reassessed taxes exceed €100,000 and an 80% (or repeated 40%) penalty applies, the case…
15 October 202511 min
Insights

French Trust Reporting Obligations: A Practical Overview

Any trust with a French connection falls within Article 1649 AB of the French Tax Code. This applies when a settlor, trustee, or beneficiary is French tax resident, or the trust…
17 September 20259 min
Insights

The French Exit Tax in a Nutshell

The French Exit Tax is an anti-avoidance measure that applies to individuals who transfer their tax residence outside France. It targets unrealized capital gains on company shares exceeding €800,000 or…
7 July 20259 min
Insights

Foreign Accounts: What French Tax Residents Need to Report

Understand your reporting duties to avoid costly mistakes. In today’s interconnected financial landscape, it is standard practice for high-net-worth and ultra-high-net-worth individuals residing in France to maintain bank or investment…
19 June 202513 min
Insights

French Tax Residency: The 183-Days Myth

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…
13 May 20251 min