As we move towards a new world marked by unprecedented volatility and growing scarcity, it is evident that we are entering an era of profound transformation. The days of low interest rates are behind us, with rates expected to remain high for the foreseeable future. In this increasingly unstable and unpredictable landscape, we find ourselves at a critical juncture.
Lire la suiteThe ownership of secondary residences in France through a Société Civile Immobilière (SCI) is a common practice among Swiss taxpayers. However, the Federal Court decision of December 13, 2022 (no. 2C_365/2021) provides significant clarifications on the tax treatment of these shares in France and its impact on Switzerland.
Lire la suiteIf you left France between March 3, 2022, and December 31, 2023, and requested to benefit from the capital gain tax suspension, you may now be exempt from the social contribution on the latent gain you had at the time of your departure. This exemption is made possible by the financial law 2024. However, it's crucial for concerned taxpayers to file a specific tax request in due course, as the timing to lodge this claim is debatable.
Lire la suiteThe Finance Bill for 2024 sets up new taxation rules for furnished tourist accommodation.
From 2024, owners of furnished tourist accommodation will be covered by the micro-BIC scheme if their turnover does not exceed €77,700 (instead of current €188,700).
Lire la suiteNowadays, Trusts can be used for a variety of purposes, such as estate planning, asset protection, and charitable giving. They offer a high degree of flexibility in how assets are managed, invested, and distributed, and can be customized to meet the specific needs and goals of the creator. The recent 2022 financial law has enacted a new limitation to this principle which should be considered for all French tax resident involved with Trust and also for those who, may consider moving to France.
Lire la suiteSince the abolition of the « taxe d'habitation » in 2023 for main residences, a new reporting obligation has been put in place.
As an owner, you are concerned by this new obligation to declare and you must indicate for each of your premises the condition in which you occupy them.
If you do not occupy them yourself, the identity of the occupants and the period of their occupation must be specified (situation on 1st January 2023).
It is usual and logical that non-residents investing in France wish to use their existing company to buy and hold the French property.
Overview on the supreme administrative court statement on 22nd July 2022 who has ruled that a Swiss company in this situation should be treated as a commercial company from a French tax purpose whilst its social object was civil.
In consequences, the shareholder cannot benefit freely from the property as it would be considered as an abnormal act, contrary to the interests of the company.
On October 5, 2021, Hong-Kong Government has issued a statement committing to amend its tax law with regards the tax exemption for foreign source passive income from 2023, to ensure the territory does not end up placed on the EU's tax blacklist of non-cooperative territories.
Lire la suiteMonaco and Dubai signed a bilateral tax treaty on the 13rd November 2021, during the Monaco day of the universal exhibition currently held in Dubai.
Lire la suiteWe are very close now to the end of the year. It is worth considering what would be your wealth tax position in France at the 1st January 2022 and if any planning should be done before the end of the year.
Lire la suiteFrench moving to Monaco are taxable to French social contributions (prélèvements sociaux) on their French income only when they are French tax resident.
Lire la suiteThe administrative supreme Court rules about a so called “convention de portage” and it impacts it could have on a share transfer tax control and on the qualification of an “occult distribution”.
Lire la suiteOn November 9, 2021, France and Belgium signed a new income tax convention which will replace the convention of March 10, 1964 at the end of the legislative ratification process in each of the states.
Lire la suiteAfter Brazil, Argentina and Uruguay, Paraguay has become a target country for the development of our activities, for private clients with interests in these countries and internationally.
Lire la suiteRegularly for 9 years, I provide training to the brilliant students at the ESCP Business School in the Executive Specialised Master in International Wealth Management. The ESCP Business School is focus on Excellence and ranked #8 in Europe.
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