When you are considered a French tax resident, you are required to report all of your income to the French tax authorities, regardless of where you earned it. Therefore, if you receive income from abroad, you are required to declare this income to the French tax authorities.
In such a case, you could potentially face double taxation. The double taxation mechanism means that the French tax resident is taxed twice. Income could therefore be taxed in two countries at the same time. This situation arises when the individual or a company is located in two separate countries that have not concluded a tax treaty with each other.
In this case, an agreement between the government of the French Republic and the government of the United Arab Emirates (" WATER "), with a view to avoiding double taxation, was signed on July 19, 1989 and amended by an amendment dated December 6, 1993 (the " France-Emirates Tax Convention ").
THE Canada is one of the most sought-after countries for immigration, for several reasons: high-quality education, universal healthcare, employment opportunities, cultural and religious diversity, etc.
As a worker and depending on your current situation, you have different options for immigrating to Canada.[1]. So, in this article, we will go back point by point over the different opportunities available to you as a worker.[2].
We will first examine federal immigration programs, namely Express Entry, the program for self-employed workers, and the business start-up visa program. These programs will allow you to immigrate to all provinces except Quebec. (I).
Then, we will discuss the programs created for young people, namely the Working Holiday Permit and the Young Professionals permit, which allow immigration more easily than other programs, from anywhere in Canada, including Quebec (II).
Finally, the programs specific to the province of Quebec will be addressed, namely the Quebec program for permanent workers, for temporary workers and for business people (III).
When you become the owner of a property in France, especially when you are not a tax resident in France, you sooner or later ask yourself the question of the taxation of this property and of inheritance. This raises the question of choosing the appropriate structure to manage the rental of a property as a family, and several options are available depending on the inheritance/tax angle you wish to prioritize.
The choice for one option rather than another will be made in particular according to the objective pursued.
What are the objects and conditions specific to the structures that can be considered?
There Non-professional furnished rental (LMNP) as for it, allows you to receive additional income from real estate while having a non-professional status.
The accommodation concerned by the rental must be furnished and the income generated cannot exceed 23,000 euros per year, nor represent more than 50% of the total income (unless non-resident) to retain LMNP status.
There Family LLC allows you to make profits while benefiting from reduced taxation. This structure is particularly recommended if the financial risk is high since the liability of the partners is limited to the amount of their contribution (in fact, the family SARL is above all an SARL).
In addition to meeting the conditions for setting up a traditional SARL, it must be made up of partners with a direct or collateral family relationship up to the second degree or through marriage.
Finally, the Family SCI is recommended with the aim of preserving and transmitting heritage from generation to generation.
The company must necessarily have a real estate activity as its corporate purpose (as for classic SCIs) and must be made up of members of the same family up to the fourth degree.
Let's look point by point at the conditions, advantages and disadvantages of these different structures which at first glance are similar but which in reality have many differences.
By introducing a corporate tax, the United Arab Emirates (UAE) wanted in particular to reaffirm its commitment to respecting international standards in terms of tax transparency and the prevention of harmful tax practices.
The tax treaty for the avoidance of double taxation between the French government and the government of the United Arab Emirates was signed on July 19, 1989 and was amended in 1993 to now also include a multilateral convention to prevent base erosion and profit shifting since the entry into force 1er January 2019 (the " Convention ").
The objectives of this Convention are multiple.
First, both countries wish to promote their economic relations and cooperation in tax matters.
Furthermore, they wish to eliminate double taxation with respect to certain taxes expressly covered by the Convention[1].
However, the Convention has provided a safeguard: the scheme or strategies put in place by taxpayers, whether individuals or legal entities, must not have the sole and exclusive aim of obtaining tax relief provided for by the Convention.
The French and Emirati taxes covered by the Convention are limited to[2] :
– income tax including in the case of real estate sales;
– tax on companies registered in France or the UAE;
The tax convention for the avoidance of double taxation and the prevention of tax evasion with respect to income taxes between the French government and the Canadian government was signed on May 2, 1975 and was amended in 1987, 1995 and 2010 (the " Convention ”) [1].
The objectives of this Convention are multiple. First, the two countries wish to promote their economic relations and cooperation in tax matters. Furthermore, they wish to eliminate double taxation with respect to certain taxes expressly covered by the Convention.
However, the Convention has provided a safeguard: the scheme or strategies put in place by taxpayers, whether individuals or legal entities, must not have the sole and exclusive aim of obtaining tax relief provided for by the Convention.
The French and Canadian taxes covered by the Convention are limited to:
income tax including in the case of real estate sales;
tax on companies registered in France or Canada; and
tax on gift tax (only for France).
This article will help you better understand the tax implications of your income between the two countries if you are an individual. If you are a business, we have also written an article to guide you.
Canada is one of the most sought-after countries for immigration, for several reasons: universal healthcare, employment opportunities, cultural and religious diversity.
Furthermore, Canada is internationally recognized for its high-quality education system, and the country welcomes many international students every year. However, to study in Canada, it is essential to obtain a study permit. This article therefore aims to provide an overview of the step-by-step procedure for obtaining a study permit in Canada and becoming a student in Canada, taking into account the specifics regarding Quebec and briefly explaining how the Canadian education system works.
We will first briefly present the Canadian study system in order to have a better understanding of the different procedures (I).
Next, we will discuss the procedure to follow regarding the study permit at the federal level outside Quebec (II).
Finally, we will explain the specific procedures to follow to obtain a study permit in the province of Quebec (III).
Cryptocurrencies appeared in the digital world around ten years ago and are now experiencing significant growth and democratization.
A virtual means of payment that can be used primarily on the Internet, using cryptography to secure transactions and the creation of units, and escaping any control by regulators and central banks, there are now more than 4,000 cryptocurrencies in circulation.
However, their legal framework is sometimes confusing and difficult to understand. This article will therefore aim to study the legislative framework for cryptocurrencies in France, Canada, and the United Arab Emirates, as well as their tax regime. We will then examine, in a non-exhaustive manner, Initial Coin Offerings, a new fundraising phenomenon based on cryptocurrencies.
What exactly are cryptos?
A cryptocurrency is a virtual means of payment that relies on cryptography to secure transactions and the creation of units, and is outside the control of regulators and central banks. Cryptocurrencies are therefore based on a computer protocol for encrypted and decentralized transactions, called blockchain.
The best known is bitcoin, which is a virtual unit of account stored electronically. However, there are now more than 4000 cryptocurrencies in circulation in the world, the best known outside of bitcoin being for example Ethereum, Ripple or even EOS, XRP, Tether, Cardan, Stellar, Chainlink, Uniswap, Polkado or even USD Coin.
Cryptocurrencies are part of the broader framework of crypoactives, which represent " virtual assets stored on an electronic medium allowing a community of users accepting them as payment to carry out transactions without having to resort to legal currency ".
The issue and circulation of digital cryptoassets is notably linked to Initial Coin Offerings (“ICO”)Unlike an IPO, the ICO is financed on digital media known as tokens (tokens). The ICO thus represents a fundraising operation operating via the issuance of digital assets exchangeable for cryptocurrencies during the start-up phase of a start-up or business project.
The tax convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital between the French government and that of Canada was signed on May 2, 1975 and was amended in 1987, 1995 and 2010 (the " Convention ").
The Convention provides specific provisions for companies and businesses established in Canada but which continue to have links with France.
The taxes covered by the Tax Convention are:
income tax including in the case of real estate sales;
tax on companies registered in France or Canada;
tax on gift tax (only for France).
We will return point by point to the different sources of income and their taxation.
Germany announced last February that it had purchased tax data of millions of people living in Dubai.
Questioned by The Echoes, the General Directorate of Public Finances has also confirmed that the sharing of this data with the French tax authorities has already taken place.
The French authorities are now seeking to identify potential fraudsters in this data and the presence of "undeclared income" and "unknown assets" of people wanting to evade tax in their country. This will include verifying whether French entrepreneurs who have gone to Dubai have paid the "exit tax" which applies to unrealized capital gains made in France and abroad (1).
This article will outline the concept of Exit Tax in order to inform French expatriates residing in Dubai about their compliance or not with French tax law due to their change of tax residence from France to the Emirates.
