“Société de conseil fiscal enregistrée à Dubaï, spécialisée dans la fiscalité France-Émirats Arabes Unis. Les questions de droit fiscal français sont traitées sous la responsabilité de Me Jonathan Sémon, avocat au Barreau de Paris.”
“Since June 2023, the United Arab Emirates has applied a 9% corporate income tax on annual profits exceeding AED 375,000. Free Zone companies may benefit from a 0% rate on their qualifying income if they meet the QFZP conditions.”
“The Tax Residency Certificate (TRC) is issued by the Federal Tax Authority (FTA) on the basis of the criteria and evidence applicable to the request.”
“Yes. For the unrealised-gain compartment, French exit tax (article 167 bis of the French General Tax Code) applies in particular where you have been French tax resident for at least six of the ten years preceding departure and your holdings meet the statutory thresholds (at least 50% of one company's profits or an aggregate value exceeding EUR 800,000).”
“This depends on the chosen regime. In Free Zones, you can own 100% of the capital without a local partner.”
“The tax liability arising from unrealised gains, earn-out claims and, where relevant, deferred gains is determined by reference to the tax rules applicable to the gains concerned at the date of the transfer of tax residence out of France.”
“Yes, if your situation falls within Article 167 bis CGI. For unrealised gains, the conditions include French tax residence for at least six of the ten years before departure and household holdings representing at least 50% of one company’s profits or securities with a total value strictly exceeding EUR 800,000.”
“No. Cryptocurrency and tokens are NOT a category of assets within the scope of exit tax application under Article 167 bis of the French Income Tax Code.”
“Yes, depending on the gain category and statutory conditions. For unrealised gains, retaining the securities may qualify for relief after the applicable period or on return to France.”
Download this profile and inspect its supporting evidence.