Cross-Border Tax Issues

Axtead supports its clients in implementing cross-border tax and wealth strategies between France and Italy, whether for relocation, investment, or estate planning.

Italy offers several highly attractive tax regimes, including:

• A flat-rate tax regime for new residents with significant income.
• A impatriate regime offering a 70% to 90% tax base reduction on professional income, depending on the region of relocation.
• A favorable gift and inheritance tax system, characterized by low rates (4% to 8%) and substantial exemptions based on the family relationship.

Our services include:

• Analyzing eligibility and ensuring access to these preferential regimes in coordination with our local Italian partners;
• Overseeing the application of the France-Italy Tax Treaty to prevent double taxation risks;
• Handling residual French tax implications, specifically regarding Wealth Tax (IFI), French-source income, and Exit Tax procedures.

Axtead advises executives, investors, and families on relocating to Spain or structuring their assets between France and Spain, with a particular focus on departures from France and cross-border successions.

Our areas of expertise include:

• Implementation of the “Beckham Law” that allows, under certain conditions, a 24% flat tax rate on Spanish-source income, with an exemption on foreign-source income for six years. We work in coordination with our local partners to secure eligibility, ensure tax compliance, and manage the transition out of the regime.
• Mitigating double taxation risks during the year of relocation: in Spain, tax residency is assessed over the entire calendar year. Moving mid-year (e.g., in August) can result in double taxation of income earned from January to August if the tax treaty is not correctly applied.
• Pre-relocation wealth structuring to optimize the Spanish Wealth Tax base, particularly regarding real estate holdings and private wealth structures.
• Management of residual French tax obligations, specifically concerning the Real Estate Wealth Tax (IFI), French-source income, and Exit Tax procedures.

Axtead advises clients on relocating to Portugal, particularly following the discontinuation of the Non-Habitual Resident (NHR) regime by the 2024 Finance Act.

The new IFICI (Incentive for Scientific Research and Innovation) regime, commonly known as NHR 2.0, applies to individuals becoming Portuguese tax residents as of January 1, 2024. This regime, more selective than its predecessor, targets highly qualified professionals (research, innovation, academia, entrepreneurship) and offers:

• A 20% flat tax rate on Portuguese-source employment and professional income;
• An exemption on foreign-source income for 10 years (excluding pensions and income from non-cooperative jurisdictions).

Our services include:

• Assessing eligibility for the IFICI regime, in coordination with our Portuguese partners, and securing the reporting and practical requirements for a change of residency;
• Managing residual French tax implications, specifically regarding Real Estate Wealth Tax (IFI), French-source income, and Exit Tax procedures;
• Supporting wealth transfers: Portugal does not apply inheritance or gift tax between close family members (spouses, children, ascendants). This makes it a highly attractive jurisdiction for family succession planning.

Axtead supports US persons residing in France, French-American families, and transatlantic investors in structuring, securing, and transferring their wealth between both jurisdictions.

Our expertise includes:

• Analysis of double taxation situations, including the application of the France-US Tax Treaty, coordination of tax residency statuses, and the strategic use of tax credits;
• Management of US trusts with French links involving French resident beneficiaries, settlors, or French-based assets: we ensure full compliance with specific French disclosure requirements (Wealth Tax/IFI and annual trust filings);
• Support for international succession and estate planning involving both countries: we work in close synergy with French notaries, the IRS, and local US counsel to secure tax and probate matters on both sides of the Atlantic.

By leveraging our cross-disciplinary expertise in international tax law and our network of specialized US correspondents, Axtead provides a consistent, secure, and compliant approach to meeting dual French-American obligations.

Axtead supports French tax residents with their projects connecting France and Israel, whether it involves Aliyah, returning to Israel, or the transfer of family wealth between the two jurisdictions.

Our expertise includes:

• Application of the France-Israel Tax Treaty to mitigate double taxation risks and identify strategic optimization opportunities;
• Estate planning optimization, that aligns with the specific civil and tax regulations of both states, and the structuring of gifts or inheritances;
• Management of Israeli Tax, working in close coordination with our local partners to manage tax implications during relocation or when holding assets in both countries;
• Handling residual French Tax obligations specifically regarding the Exit Tax, Real Estate Wealth Tax (IFI), and French-source income.

Axtead supports you at every step to structure, transfer, and secure your wealth within a compliant and sustainable cross-border framework.

Axtead advises Belgian tax residents with French-based assets, as well as French taxpayers planning to relocate to Belgium.

We ensure seamless coordination between the French and Belgian tax systems, with a particular focus on:

• Real Estate Wealth Tax (IFI), applied to non-residents exclusively on their real estate assets located in France;
• Belgian Tax on Securities Accounts (0.15% tax on accounts exceeding €1M), including those held abroad;
• Residual French Tax post-departure matters (French-source income, Exit Tax, IFI reporting);
• Anticipating and managing international cross-border wealth transfers in full compliance with the relevant legal and tax frameworks.

Our approach aims to secure wealth flows between both states, driven by strategic foresight, compliance, and tax optimization.

As of April 2025, the British tax system has undergone a fundamental reform, marked by the abolition of the remittance basis and the introduction of the Foreign Income and Gains (FIG) regime.

Axtead assists its clients in navigating these new rules and transitional measures, including:

• Application of the FIG regime for new residents (four-year exemption on foreign income and gains, even if repatriated);
• Potential combination with the Overseas Workday Relief (OWR), limiting taxation on foreign employment income for up to three years;
• New Inheritance Tax (IHT) regime based on tax residence rather than domicile: 10-year exemption for non-UK assets, with a “tail provision” maintaining IHT exposure for several years after departure;
• Abolition of Excluded Property Trusts regime (transparent taxation of the trust unless the settlor qualifies for the FIG regime).

Our services include:

• Assessing and securing access to preferential regimes in coordination with our UK-based partners;
• Applying the France-UK Tax Treaty to prevent double taxation;
• Managing residual French tax obligations, specifically Exit Tax, French-source income, and IFI (Wealth Tax) reporting.

Axtead supports executives, entrepreneurs, and high-net-worth families in structuring and securing their wealth operations between France and the Gulf States (United Arab Emirates, Saudi Arabia, Qatar, etc.).

We advise on relocation, cross-border investments, and estate planning, combining French tax expertise with operational knowledge of local specificities.

Our assistance covers:

• Tax residency analysis, managing relocation to income-tax-free jurisdictions, anticipating recharacterization risks, and organizing the formal exit from the French tax system;
• Cross-border real estate structuring, securing favorable treaty-based regimes, particularly regarding the French Real Estate Wealth Tax (IFI), where applicable;
• Managing international wealth transfer (gifts, successions) in environments often not covered by bilateral inheritance tax treaties, requiring proactive planning regarding French tax exposure;
• Handling residual French tax obligations such as French-source income, capital gains, and IFI reporting.

We ensure seamless coordination with local professionals (tax advisors, private bankers, family offices) to guarantee the legal and tax coherence of all structures.

Axtead advises clients on the structuring, transfer, and protection of their wealth between France and Switzerland, whether for relocation, cross-border asset holding, or international estates.

Our expertise includes:

• Tax residency management, navigating the complexities of the France-Switzerland Tax Treaty and mitigating dual-residency risks;
• Strategic planning for expatriation or returning to France, with a comprehensive analysis of the tax regimes in both jurisdictions;
• French real estate structuring, through optimal vehicles, balancing legal compliance with tax efficiency;
• Succession coordination, anticipating civil law discrepancies (heirship–réserve héréditaire–, succession agreements–pactes successoraux) and managing double taxation risks in wealth transfers.

We adopt an integrated and secure approach, working in close collaboration with our clients’ Swiss advisors to ensure the consistency of wealth management decisions across the Franco-Swiss border.