PractiCe areas / OUR EXPERTISE 

Our firm offers to individuals and professionals legal advisory and litigation services mainly in tax law.

We represent our clients in French courts, provide legal advice in non-litigious matters and draft agreements and other legal documents.

Our clients rely on us to bring a distinctively high degree of quality to resolve their legal challenges effectively and cost-efficiently.

We help with :

- Tax litigation 

- French income tax returns, Wealth tax returns, Trusts;

- French taxes concerning inheritance, revenue, immovable and movable assets and capital gains (CGT);

- International tax affairs;

- Tax affairs of those who work in aviation and aircraft manufacturing;

- Legal assistance for airline transport pilots and instructor pilots;

- Assistance with property purchases in France; 
- Assistance for Professional Rugby players

Trust law is particularly complex in France, as the French legal system (civil law) ​​​​​​​does not have an exact equivalent.  Karl G. Fuzel regularly advises on these issues, particularly regarding:
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• Tax compliance: Specific annual and event declarations for trusts. 
• International successions: Management of the transfer of assets located in France or to French resident beneficiaries via a foreign trust.
• Consulting and optimisation: Analysis of the impact of French tax law on trustees, settlors, and beneficiaries.

As we are accustomed to working with an international and English-speaking clientele, we have a thorough understanding of the nuances between Common Law systems (United Kingdom, USA, etc.) and French tax law.

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We prepare and file :
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- Income tax returns
- Wealth tax returns
- Capital gains tax declaration Re sale of foreign immovable assets-
- Trust annual tax returns
- Exit tax returns

Expertise in the "3% Tax" on French real estate entities and optimisation of property acquisition vehicles (SCI, OPCI, SIIC).

We advise institutional investors and high-net-worth individuals on the French Real Estate Wealth Tax (IFI) and capital gains on property disposals.

Protecting the interests of individuals and families across borders

• Estate Planning: Structuring international inheritances and donations involving multi-jurisdictional assets and trusts.
• Tax Residency: Advising on change of residence, "exit tax" implications, and the special regime for impatriates.
• Asset Optimisation: Managing Wealth Tax (IFI) exposure and optimizing investment income through the Flat Tax (PFU) mechanism

Tax Expertise for Professional Rugby
Specialised French Tax Solutions for Top 14 & Pro D2 Athletes

The French Challenge

Playing in France offers prestige and competitive salaries, but the tax system is complex:

High Marginal Rates

Income is taxed up to 45% for high earners in the Top 14.

Exceptional Contribution

An extra 3% to 4% (CEHR) surcharge applies to high-income individuals.

Our goal is to mitigate these costs legally while ensuring full compliance with the DGFiP.

Art. 155 B: The "Red Carpet"

For players arriving from abroad, the Impatriate Regime is the ultimate optimisation tool:

8-Year Duration

Exemptions apply for up to 8 years if you haven't been a French resident in the last 5 years.

50% Exemption

Up to 50% of your total remuneration can be exempt from French income tax.

Passive Income

50% exemption on foreign dividends, interest, and capital gains while playing in France.

Salary vs. Impatriation Bonus

Strategic contract structuring allows for a specific "Impatriation Bonus" that is fully exempt from tax, provided the base salary remains comparable to French peers.

Image Rights: Royalties

Licensing Agreement

Social Security Hedge

Royalties are not subject to the high French employee social security contributions (approx. 20-23%), saving significantly for the athlete.

Legal Security

We ensure contracts meet "Model Treaty" standards to avoid reclassification as "modelling salary" by tax authorities.

Days Worked Abroad

Champions Cup, 6 Nations, and international tours are key opportunities for tax savings.

Pro-Rata Exemption

The share of your remuneration corresponding to days worked outside France is 100% exempt from French tax under the impatriate regime.

Wealth Tax Protection

Foreign Asset Exemption

The Impôt sur la Fortune Immobilière (IFI) only targets French real estate for eligible impatriates.

Debt Structuring

We advise on debt-financed acquisitions of French property to stay below the €1.3M Net taxable threshold.

Securing Your Transition

Investing for the Future

•  Assurance-Vie: The gold standard for French wealth accumulation and tax-efficient withdrawals.
•  PER (Retirement Plan): Deduct contributions from your high-taxable income today to save for tomorrow.
•  International Portfolios: Optimised management of assets held in your home country.

Strategic Fiscal Optimisation for Pilots & Aerospace Engineers in Toulouse
Optimisation of multi-state income, Article 81A exemptions, and social security coordination for long-haul crews.

Article 81 A Regime

French-resident pilots performing international missions can benefit from significant tax exemptions on their foreign-sourced income.

• Exemption based on days spent abroad (120/183 days).
• Strategic management of per diems and specific bonuses

Article 155 B Benefits

Designed for professionals recruited from abroad to work in France.

• 8-year exemption for "Impatriation Bonus".
• 50% exemption on foreign passive income (dividends, interest).
• Flat 30% bonus estimation if not detailed in contract.

Unlocking Massive Savings

50% Tax Exemption Cap

Impact on Net Income : the impatriate regime can legally reduce your taxable base by up to 50%, provided your net taxable income remains comparable to a local peer.

For an executive earning €150k, this can represent €30k+ in annual savings.

Variable Income Management

Stock Options
Optimisation of AGA and BSCP plans specifically for the aerospace sector's global standards.

Profit Sharing

Strategic reinvestment of "Participation" and "Intéressement" into tax-sheltered PEE/PER plans.

Social Charges

Minimising CSG/CRDS impact on foreign income for non-French social security affiliates.

Our Audit & Compliance Process

Initial Audit

Review of status, income source, and residency history.

Strategy Design

Tailoring Art. 81A or 155B options for maximum gain.

Compliance

Drafting of annual tax returns and supporting files.

Wealth Planning

Long-term investment and inheritance structuring.

Tax Treaties and Double Taxation in French Law

Overview of the hierarchy of norms, interpretation methods, and unilateral relief mechanisms in the absence of tax conventions.

The Role of Double Tax Treaties

Global Context

Tax treaties (Conventions fiscales) are bilateral agreements designed to allocate taxing rights between two sovereign states. Their primary goal is to foster international trade by removing the barrier of double taxation.

Key Objectives

Beyond avoiding double taxation, modern treaties aim to prevent fiscal evasion, promote information exchange, and provide dispute resolution mechanisms through Mutual Agreement Procedures

Article 55: Supra-legislative Status

• Constitutional Primacy: Under Article 55 of the French Constitution, ratified treaties prevail over domestic statutes.
• Direct Applicability: Once published, tax treaties can be directly invoked by taxpayers to override conflicting domestic laws.
• Reciprocity: The superiority of the treaty is subject to its application by the other contracting state.

The Principle of Subsidiarity

Step 1: Domestic Law

Analyze if the income is taxable under the French General Tax Code (CGI). Domestic law is always the starting point.

Step 2: Treaty Test

Verify if the treaty limits France's right to tax. The treaty can only reduce the tax burden, not create it.

The Schneider Case

The landmark Schneider Electric (2002) ruling confirmed that treaties serve only to restrict or eliminate domestic taxing power

Fundamental Interpretation

"An international tax treaty can never, by itself, serve as a legal basis for taxation; it can only lead to the reduction or elimination of the tax that would be due under domestic law."

— French Administrative Supreme Court (Conseil d'État)

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Corporate Taxation: Territoriality

Article 209-I of the CGI

France applies a unique Territorial Principle for corporate tax. Only profits made from businesses operated in France are taxable.

Profits realized through an autonomous establishment or a complete business cycle abroad are exempt in France, effectively preventing double taxation at the source.

Participation Exemption Regime

To avoid economic double taxation of inter-company profits, France exempts almost all dividends received from subsidiaries (minimum 5% holding, 2-year period).

Methods for Eliminating Double Taxation

Treaties either allow a credit for foreign tax paid or exempt the income while including it to calculate the global tax rate.

• Tax Credit Method (Most Common)
• Exemption with Progression

Absence of a Tax Convention

• Unlimited Tax Liability: In the absence of a treaty, French tax residents are taxable on their worldwide income.
• No Tax Credits: Unilaterally, French domestic law does not grant a tax credit for taxes paid in a non-treaty foreign state.
• Risk of Actual Double Taxation: Since no credit exists, the same income may be taxed at full rates in both jurisdictions.

Unilateral Remedy: Deductibility

Tax as an Expense

While no credit is available without a treaty, France allows the deduction of foreign tax paid as a professional expense or charge from the taxable base.

• Income is reported "Net of Foreign Tax."
• Reduces the base, but doesn't fully offset the double tax burden.

Anti-Abuse and Modern Trends

MLI and BEPS

France was a pioneer in adopting the Multilateral Instrument (MLI), which automatically updates bilateral treaties with anti-abuse provisions (Principal Purpose Test).

Special vigilance is applied to "Non-Cooperative Jurisdictions," where withholding taxes can reach 75% regardless of treaty provisions.