International mobility lawyer in France – Expatriation, Secondment & Cross-Border Work

I advise executives, international artists and professional athletes on the legal and tax implications of cross-border mobility. Whether relocating to France, moving abroad, or carrying out professional activities across multiple jurisdictions, my role is to secure strategic decisions and mitigate the tax and social security risks inherent in international mobility.

Structuring a change of tax residence

A thorough preliminary review of the change of tax residence is essential, whether the move involves leaving France or establishing residence in France. A mere physical relocation does not, in itself, determine tax residence: an individual may remain treated as a tax resident of their country of origin or, conversely, become a French tax resident sooner than anticipated, thereby being subject to taxation on worldwide income and gains.

Cross-border moves also create potential exposure to double taxation between the jurisdictions involved, which may give rise to complex and costly disputes. Anticipation is therefore critical. I conduct a detailed review of the client’s personal, professional and financial circumstances in order to structure a tax residence position that is robust under domestic law and defensible under applicable tax treaties.

Assessing the tax implications of a change of residence

A change of tax residence entails a range of tax consequences that must be carefully assessed in advance. In the case of a departure from France, certain taxpayers may fall within the scope of the French exit tax regime, notably in relation to unrealised capital gains on shareholdings or financial assets. In the case of a move to France, particular attention must be paid to the tax treatment of foreign-source income and assets, as well as to reporting obligations.

The analysis also extends to anticipated income streams — dividends, capital gains, royalties, employment income and real estate income — in order to determine how taxing rights are allocated between jurisdictions under domestic legislation and applicable tax treaties. The objective is to avoid unexpected tax exposure and ensure a controlled and compliant transition.

International coordination

As a Delegate to the International Bar Association, I work closely with foreign counsel in the relevant jurisdictions to anticipate the tax and legal implications of a relocation and to coordinate the implementation of the mobility strategy. This approach makes it possible to review the structuring of assets and professional activities either before or after the move.

International mobility extends well beyond tax considerations. Immigration status, social security coverage, employment law, corporate structuring, succession matters and wealth planning must be addressed in a coherent and integrated manner. A coordinated cross-border strategy enables clients to optimise their position in their new environment while ensuring full compliance with applicable regulations.