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Wednesday, October 08th, 2008
Summary: This article provides a brief overview of certain interesting features of the French taxation system and a consideration of 'France Offshore'.
A consideration of interesting tax anomalies in France.
This article provides a brief overview of certain interesting features of the French taxation system and a consideration of ‘France Offshore’.
Though France is not considered an offshore jurisdiction, nor is it generally considered an attractive location for individuals or companies seeking to limit or reduce their taxation, there are certain features particular to the French taxation system that can make France an attractive country in terms of taxation for certain individuals or companies in certain situations, making France Offshore a real concept for some.
An example of which is the French treatment of “co-ordination centres”. These are the headquarters or logistics centres of foreign multinational groups and they can be afforded favourable taxation treatment if they adhere to certain rules and meet certain guidelines.
The guidelines for the establishment of a business as a “co-ordination centre” for taxation purposes state that the centre has to be involved in the stocking, labelling, packaging, distribution, control or co-ordination of the administrative and logistic activities for and on behalf of a group of enterprises under common ownership but with a multinational geographic dispersal.
If a company meets these general guidelines and is accepted as being a “co-ordination centre” for the purposes of taxation they will pay reduced corporate income tax on a fixed sum amounting to 6-10% of “operating expenses”. The actual percentage depends on the operational structure of the co-ordination centre and its proposed activities and if either of these factors change after the granting of co-ordination centre status the taxation percentage factor can change too.
Sometimes it’s possible for the management of a co-ordination centre to make arrangements for expatriate management to receive certain tax benefits and breaks in France as well. But as there is no scheme and no fixed guidelines in this area, individual negotiation is required.
If you are considering moving to France or establishing a business in France, Shelter Offshore can assist you. We can put you in touch with offshore advisers and specialists in the taxation field or we can supply you with further information depending on your requirements.
We look forward to hearing from you.
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