Tax and structuring counsel for inbound investment into France
We design and defend the tax side of cross-border structures: holdings above French targets, the mère-fille participation regime and tax consolidation, withholding on dividends, interest and royalties, transfer-pricing documentation and audits. The aim is structures that survive scrutiny — built on substance, documented properly, and explained to the group in plain language.
When this practice applies
Bring this practice in before the structure is set: at acquisition, when a holding is being located, when financing is being sized against interest-limitation rules, and when intra-group flows — dividends, fees, royalties — are being put in place.
It also acts when the French tax authority calls: documentation requests, audits, adjustment proposals and the litigation that sometimes follows.
Our approach
- Map the flows: who pays what to whom, under which treaty and which domestic regime
- Locate the holding: substance, anti-abuse rules and the participation regimes that apply
- Size the financing: interest-limitation stack, related-party rates, hybrid checks
- Document: transfer-pricing files, intra-group agreements, the paper that wins audits
- Defend: audit strategy, adversarial phase, settlement or litigation as the file deserves
Scenarios we handle
Holding structures
Location, substance and the participation regimes above French operations.
Withholding & treaties
Dividend, interest and royalty flows; treaty relief procedures and certificates.
Transfer pricing
Policy, master and local files, the annual declaration and audit defence.
Tax controversy
Audits, adversarial proceedings and litigation before the French courts.
The team on this
Selected matters
- Restructuring the European holding chain above a French industrial subgroup ahead of a refinancing.
- Documenting the transfer-pricing position of a foreign-owned French distributor through a full audit cycle.
- Advising a family office on the French tax treatment of a mixed real-estate and operating portfolio.
Fees
Structuring work is quoted as a fixed fee per defined deliverable — memo, structure paper, documentation set. Audit defence runs on phase budgets. We state the basis in writing before starting; figures are a first-call conversation, not a website claim.
FAQ
Which withholding tax applies to dividends leaving France?
The starting point is the domestic withholding rate, but three layers can reduce it: the EU parent–subsidiary regime, the mère-fille mechanics, and the applicable double-tax treaty. What rate actually applies turns on shareholding level, holding period, beneficial ownership and the substance behind the recipient. The relief is only as good as the paperwork — residence certificates and forms filed on time — which is where most of the practical failures happen.
When is a French holding company worth setting up?
When there is something real for it to do: consolidate French operations under intégration fiscale, pool financing, prepare a partial exit, or anchor management. A French holding with substance benefits from the participation regimes on dividends and long-term capital gains. A letterbox added only for treaty access is precisely what anti-abuse rules now catch — so the honest analysis sometimes concludes that no new entity is needed at all.
What does a French tax audit look like in practice?
It opens with a notice defining scope and years, proceeds through information requests and meetings, and ends with either a clean closure or an adjustment proposal that opens an adversarial phase with real procedural rights. Transfer pricing, management fees and financing costs are the recurring battlegrounds for foreign-owned companies. Files prepared before the audit — not reconstructed during it — are what keep adjustments and penalties contained.
General information, current as of 18 June 2026. Not legal advice. Subject to applicable law.