In brief: LightHouse LHLF supports groups and companies in their cross-border operations: tax treaties, withholding taxes, permanent establishment and international structuring.
International taxation governs the taxation of flows and structures between several States: dividends, interest, royalties, services, establishments. Between tax treaties, European directives and anti-abuse rules, each cross-border transaction requires careful analysis to avoid double taxation. We structure and secure your international operations.
Treaty application, elimination of double taxation, anti-abuse clauses: we secure the treatment of your cross-border flows.
Dividends, interest, royalties: we optimise and secure withholding taxes on your inbound and outbound flows.
We assess the permanent establishment risk of your activities abroad and secure your international presence.
Holdings, establishments, intra-group financing: we design compliant and efficient structures.
Closely linked to international taxation, your transfer pricing is set, documented and defended by our dedicated team.
Expatriate or impatriate executives and employees: we handle tax residence and income taxation.
We defend you during audits of your international operations and in mutual agreement procedures.
It is a bilateral treaty between two States designed to avoid double taxation and allocate taxing rights. It prevails, under conditions, over domestic law.
It is a fixed place of business through which a company carries on its activity in another State, making its profits taxable there. Its assessment is a major tax risk issue.
Through the application of treaties (exemption or tax credit) and, in the event of a dispute, through mutual agreement procedures between authorities. We manage these mechanisms.
As soon as a flow, establishment, financing or reorganisation crosses a border: anticipation avoids tax costs and heavy litigation.