À compter du 1er juillet 2025, l’Italie applique un taux unique de TVA réduit à 5 % sur les cessions et importations d’œuvres d’art, objets de collection et antiquités. Cette réforme, rendue possible par la directive UE 2022/542, positionne l’Italie comme le marché le plus attractif d’Europe pour les acteurs du secteur artistique : galeries, marchands, collectionneurs et artistes.

Popularisé par le cas de Cristiano Ronaldo, le régime fiscal italien des néo-résidents permet, sous conditions, de bénéficier d’une imposition forfaitaire sur les revenus de source étrangère. Cette note détaille les conditions d’accès, les avantages, les obligations déclaratives, ainsi que les précisions issues des circulaires de l’Agenzia delle Entrate.

Discover how Italy's 2025 tax reform affects the taxation of trusts under the inheritance and gift tax regime, and the resulting cross-border challenges.

Ensuring a tax residence transfer requires a thorough analysis of personal, professional, and asset-related criteria under both domestic and bilateral tax law. This article outlines how these rules apply between France and Italy.

The Nordcurrent Group judgment delivered by the CJEU on 3 April 2025 (C-228/24) clarifies that the anti-abuse clause of the Parent-Subsidiary Directive applies only if two cumulative conditions are met: the existence of a non-genuine arrangement and a tax purpose contrary to the directive’s objective. The analysis must consider all relevant facts, including those preceding the dividend distribution, and take into account the actual tax burden borne—particularly where the corporate income tax rate in the subsidiary’s State is higher.

The Paris Administrative Court of Appeal clarified the scope of the French anti-abuse provision by ruling out its application to a foreign company exploiting the image rights of an athlete domiciled in France. By accepting the fair market value of the company’s assets at the date of the taxpayer’s change of tax residence as the relevant criterion for assessing the financial predominance of the assets, the court confirmed that the image rights represented the company’s main asset, thereby excluding the taxation of its income in France.

Subsidiary, branch, or liaison office: legal, tax, and administrative aspects to consider when establishing a presence in France

A recent administrative court judgment refines the conditions under which a company may validly compensate its director indirectly through a service agreement.

The French tax authorities have just released the deadlines for filing your 2024 income tax return, to be submitted in 2025. This provides an opportunity for our team to share some key reminders to help you approach this new filing season with confidence: foreign accounts, irrevocable election for progressive rates on investment income and capital gains, deferred capital gains, impatriate regime, non-professional furnished rentals, departure from France, and exit tax.

Understand how crypto gains are taxed in France: capital gains, business income, non-commercial business income, staking, airdrops, and.. the risks of requalification by tax authorities.

For the year 2025, French tax residents with annual income exceeding €250,000 for single taxpayers and €500,000 for married couples or those in a civil partnership will be subject to an effective minimum tax of 20%. This mechanism is designed to ensure that their level of taxation does not fall below this threshold, a situation previously possible mainly due to the 12.8% flat tax on certain gains and income from financial assets. In this article, we will use numerical examples to illustrate how this tax operates and help our readers better understand its overall fiscal impact.

Introduced in the 2025 Finance Act, the new Article 163 bis H of the French Tax Code establishes that, as a rule, gains from management packages are taxed as employment income. However, a portion of the gain may qualify for capital gains treatment where the beneficiary has genuinely borne investment risk. This article deciphers the mechanism, explains the legal formula, outlines the eligibility conditions, and highlights cross-border implications.

In the coming decades, the world is poised to experience the largest intergenerational transfer of wealth in history. Known as the "Great Wealth Transfer," this unprecedented phenomenon will see substantial assets shift into the hands of younger generations, reshaping economic balances.

France stands out internationally by offering attractive tax and social security regimes designed to encourage the arrival of inbound taxpayers—individuals transferring their tax residence to France for work and life. In addition to the well-known impatriate tax regime, France offers several complementary advantages. In this article, I present four key mechanisms that can help reduce the tax and social security burden for those relocating to France.

When faced with a request for information from the tax authorities, it is crucial to act promptly. Regularization cases can be particularly complex and time-consuming, especially due to the administration's right of reassessment.

In a landmark ruling dated 8 November 2024 (CE, no. 471147), the French Conseil d’État reaffirmed the importance of demonstrating beneficial ownership (BO) to benefit from withholding tax (WHT) exemptions on outbound dividends. The case involved a French subsidiary distributing dividends to its Luxembourg parent company, which immediately transferred the funds to its sole shareholder. I analyse here the key takeaways from this decision, with a focus on its legal basis, reasoning and practical impact for international groups.

The October issue of Ingénierie Patrimoniale (Journal of Wealth Engineering - JFA) features an in-depth article by Sandro Assogna, lawyer and founder of TaxLhab, on Italy's new optional early payment regime for inheritance and gift tax (ISD), effective from 2025 on asset transfers from trusts.

Digital transformation and increased international mobility have given rise to new professional figures – influencers, e-athletes, sextertainers and edutainers – whose activities often span multiple jurisdictions. In this article, I provide a practical overview of the international tax issues that may arise from such cross-border activities, based on the general principles of business income taxation and the key provisions of tax treaties.

France offers a specific tax regime for inbound employees (the "impatriate regime") designed to attract international talent. As a French tax lawyer, I regularly assist executives and companies in making the most of this regime, which can provide substantial income tax exemptions for up to eight years. In this article, I explain how it works, who qualifies, what the options are, and how to choose the best strategy.

An important decision regarding the application of the Contribution exceptionnelle sur les hauts revenus (CEHR) on French-sourced dividends paid to an Italian resident

Italy offers a favorable tax regime for retirees who decide to transfer their tax residence to the country, aiming to attract investments, stimulate consumption, and bring resources to the southern regions. This regime allows for a substitute tax of 7% on foreign income for a maximum duration of 9 years.

The most significant novelty of the reform is the introduction of an optional regime of advance taxation at the time of the transfer of assets to the trust or the opening of the estate.