TAX

Last update of this article: November 13, 2025 Decision of 30 September 2025, No. 490793 This recent ruling of the Conseil d’État (France) is directly relevant for French operators who make royalty or service payments to non-resident beneficiaries and question the application of the withholding tax under Article 182 B of the French General Tax […]

Last update of this article: 26th september 2025 Our firm has advised private clients and families for nearly 10 years in international estate and gift taxation, with a sustained focus on France–Italy and France–United States crossborder matters.  On our French, English, and Italian blogs, we regularly analyze these topics for a cross-border audience. We are

Last update of this article: 6th august 2025 In 2025, a French court confirmed that life insurance held by a US irrevocable trust may be taxed as an indirect gift in France. Here’s what Franco-American taxpayers must know to stay compliant. Focus on French-American Case Law Life insurance in an irrevocable trust: indirect gift? Decision

Last update of this article: may 2025 Many families are unaware that a tax-free donation in France is possible under a temporary scheme. In a Franco-Italian context where wealth transfer is a major concern, the 2025 Finance Act introduces an exceptional scheme: Article 790 A bis of the French Tax Code. Below is the full

Last update of this article: march 2025 In any tax system, tax residency is a fundamental principle that determines which subjects, whether individuals or legal entities, are required to pay taxes due to their physical presence in the territory of a state. Regarding individuals, tax residency is generally established according to different alternative criteria, ranging

Last update of this article: march 2025 PART TWO – Companies and Entities In the FIRST PART of our article on Circular 20/E dated November 4, 2024, we examined how the Italian Revenue Agency (i.e., the Italian tax authority Agenzia delle Entrate) provided its interpretative reading of the legislative amendment introduced by the “International Taxation”

Last update of this article: february 2025 FIRST PART – Individuals In Circular 20/E dated Nov. 4, 2024, the Agenzia delle Entrate (i.e., the Italian tax administration – the Agency) gave its interpretative reading of the legislative change of the “International Taxation” Decree (Legislative Decree 209/2023) regarding the tax residency of individuals and companies. As

Last update of this article: october 2024 Article 24-bis TUIR (Italian Tax Code) What Are the Key Requirements for the Italian Flat-Tax Regime? Who Can Opt for It? What Are the Main Benefits? Are There Any Special Conditions or Exclusions? The €200,000* Flat-Tax regime under Article 24-bis of the TUIR is designed to attract high-net-worth

Are you planning to move to Italy and become an Italian tax resident?If so, it’s essential to understand that your foreign-owned real estate and financial assets may be subject to Italian wealth taxes, specifically IVIE and IVAFE. In this article, we explain how these two Italian wealth taxes work, how they are calculated, and what

In our previous article, we saw how the first tool of Gift/Inheritance Tax optimization is taking advantage of the Tax Allowances provided for by the French Tax Code.  We saw that the amount of the Tax Allowances vary according to the relationship between the beneficiary of the gift and the donor. We also saw that