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Ask us directlyTax Services Across France
Files that look like this one
Canadian who took a post in France and kept a flat
A professional moved to France for a fixed-term post and kept an apartment in Canada, letting it while away. The letting agent had remitted nothing to the tax authority and no election had been made, so the rent had been flowing gross for two years. We established the date residency ended, filed the final resident return, put the non-resident withholding on a proper footing and made the election that allows the rent to be reported net of expenses. The engagement produced a corrected filing history, an accepted election and returns filed for both years.
French group setting up its first Canadian subsidiary
A group based in France incorporated a Canadian company to serve customers in North America and had no Canadian filing calendar at all. We identified the first corporate return and its due date, dealt with sales tax registration, priced and documented the services the parent was providing, and reviewed how the subsidiary was to be funded before the loans were drawn rather than after. The engagement produced a filing calendar, an intercompany agreement, transfer pricing documentation for the first year and a funding structure the group understood before committing to it.
Retired couple in France drawing Canadian registered savings
A couple who had retired to France were drawing on Canadian retirement savings and had tax withheld on every payment, with nothing claimed on either side. We confirmed how the treaty treats periodic payments from plans of that kind compared with lump-sum withdrawals, adjusted the way the withdrawals were taken, and prepared the Canadian filings so their French adviser could claim relief against the correct amount. The engagement produced a corrected withholding position, Canadian returns for the open years and a withdrawal pattern chosen with the treaty treatment in mind.
Sale of a Canadian house by an owner now living in France
An owner who had emigrated to France sold the house she had lived in before leaving. Part of the price was held back at closing, as it must be when the vendor is not resident, and the question nobody had asked was how much of the gain the principal residence rules still sheltered for the years she lived there. We worked out the sheltered period, filed the notification with the cost history, obtained the certificate and prepared the return. The engagement produced a documented gain calculation, a clearance and the release of the held-back amount.
Author in France receiving royalties from a Canadian publisher
A writer resident in France was paid royalties by a Canadian publisher which withheld at the domestic rate because it held nothing on file to show where she lived. The treaty limits withholding on royalties of that kind, but only for a payer who has been told and given evidence. We provided the publisher with the residence documentation it needed, corrected the deduction going forward and filed to recover the excess taken in the years still open. The engagement produced a corrected payer record and recovered withholding that had been over-deducted.
Estate of a Canadian who died while living in France
A family had to settle the Canadian affairs of a parent who had spent her last years in France. Property remained in Canada, the final return had not been filed, and the executors were being pressed to distribute. We prepared the terminal return, valued the property treated as disposed of at death, coordinated with the notaire handling the succession, and applied for the clearance the executors needed before distributing anything. The engagement produced a filed terminal return, a documented set of date-of-death values and the clearance itself.
Information Returns Missed Behind a Correct Return
The heaviest exposure on a cross-border file is often a disclosure form rather than the tax. Where the return itself was right, the procedures for late information returns turn on a reasonable-cause narrative with dates and documents behind it.
Read how this one runsA Shareholder Loan Across a Border at No Interest
An interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
