For several years now, France has been engaged in negotiations with many States traditionally known for their leniency and discretion in welcoming foreign capital.

This momentum was originally initiated by the USA, which, thanks to their various levers of pressure, paved the way for other States, such as France, towards international tax transparency.

In recent years, tens of billions of euros of assets held abroad by French residents have been regularised, a large part of them from Switzerland. Tax lawyers have been in great demand.

In practical terms, today, if you wish to conceal assets, Switzerland is no longer the right destination. Since 2018, a systematic exchange of data has been in place between France and Switzerland. It is therefore no longer possible to slip through the French tax net by sheltering one’s capital in Switzerland. Your tax lawyer can help you regularise this capital.

Another State was until now known for its welcoming attitude towards the capital of French nationals, with the utmost discretion: Israel. Here too, the floodgates are closing. Since 1^st January 2017, Israel is supposed to communicate to the French tax authorities the identities of its nationals holding assets there (mainly bank accounts).

More specifically, Israeli banks are currently classifying their clients on the basis of their tax number. The identities of holders of French tax numbers will very probably, in the near future, be communicated to the French tax authorities.

It remains to be seen how the French tax authorities will process this data. Will they have the material and human resources to process the entire file? Will they sort it by types of profiles that are more interesting than others in terms of possible reassessments? We do not know at present.

But one thing is very likely: this data will soon be communicated by Israel to the French State.

At the same time, the Minister for Public Action and Accounts, Mr Darmanin, announced the forthcoming end of the voluntary regularisation scheme for foreign accounts, which made it possible to benefit from reduced penalties.

This scheme ended on 31 December 2017. This marked the end of the special unit that had been created, the STDR (service de traitement des déclarations rectificatives, the unit processing amended returns).

If you wish to regularise your situation, voluntary regularisation remains possible with the competent tax office, but without a scale of reduced penalties. A tax lawyer can help you.

Do not hesitate to get in touch to consider whether it is advisable for you to regularise your situation.

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