International Accountant for Cross-Border Businesses

A foreign company opening in France, an entrepreneur running a US LLC from Paris, a director moving to France under the inpatriate regime: each of these plays out on the French side of an international structure, with choices that commit you for years.

An international accountant secures the French side of a cross-border activity: helping a foreign company choose between a branch, a subsidiary or a permanent establishment, keeping the French accounts and tax filings (corporate tax, intra-EU and non-EU VAT, tax return), applying the inpatriate regime (article 155 B) to an incoming director, and coordinating with your advisors in the home country. We do not handle foreign accounting, but we make everything on the French side reliable.

This is the first decision to make. A foreign company that wants to operate in France chooses between two structures registered with the trade and companies register (RCS), through the INPI single window, or ends up with a de facto permanent establishment.

The branch

A branch (succursale) has no legal personality separate from the parent company: it is a permanent extension of the foreign business in France, with its own premises. It constitutes a permanent establishment, so it is subject to French corporate tax on the profit attached to the French activity and must register for VAT. The parent company remains legally liable for the branch's commitments.

The full branch walkthrough, from apostilled articles to the first filing of accounts, is in our guide to opening a branch in France.

The subsidiary

A subsidiary (filiale) is a company incorporated under French law (usually a SASU or a SARL) with its own legal personality and assets, even if its capital is held by the foreign company. It ring-fences liability, eases local banking and commercial relations, and falls fully under French corporate tax (15% up to 42,500 euros of profit under conditions, then 25%). It is often the clearest structure for a lasting presence.

Setting up a subsidiary is covered in our legal, tax and HR guide to the French subsidiary.

The de facto permanent establishment

A foreign company with no dedicated structure can still create a permanent establishment in France (premises, staff, a full commercial cycle run from France). It then becomes taxable on the attached profit in France without having planned for it. Conversely, a foreign company with no permanent establishment must still register for French VAT from its first taxable transaction, and for corporate tax if it owns real estate in France or runs a property-dealing business. Our role: qualify the situation upfront to avoid an imposed reclassification.

This is a frequent case, often poorly anticipated. A French tax resident who owns a US LLC (or a UK Ltd) and runs the activity from France exposes the company to the risk of an effective place of management in France, hence a permanent establishment and French taxation, on top of personal reporting obligations (form 2047 for foreign-source income, form 3916 for accounts held abroad, the article 123 bis rule for certain structures).

Our frequent recommendation, once the situation is mapped: set up a French SASU to carry the French activity. You gain clarity, end the reclassification risk, benefit from corporate tax at 15% then 25%, and B2B services supplied outside the European Union fall outside the scope of French VAT (the place of taxation follows the customer). We handle the French side; US obligations (US returns, K-1 on the US side) remain your local CPA's responsibility, and we coordinate with them.

An employee or an assimilated-employee director coming to work in France may benefit from the inpatriate regime of article 155 B of the French tax code, provided they were not tax-resident in France during the five calendar years before taking office, and settle their home in France. The inpatriation bonus is exempt from income tax for its actual amount or, by election, for a flat 30% of total net remuneration. The benefit applies until 31 December of the eighth year following the start of duties. The net-pay gain is often decisive in attracting an international director, provided the regime is documented from hiring.

The regime is covered in full, ceilings and durations included, in our inpatriate regime guide, and the LLC comparison in French subsidiary or branch for a US LLC.

VAT is the operational topic that comes up most often. We secure: intra-EU supplies and acquisitions, the VAT recapitulative statement and the European services declaration (DES), reverse-charge import VAT, the B2B services regime (taxable where the customer is, hence outside the French scope when the client is outside the EU), the French VAT registration of a foreign company, and the EORI number for import-export. A territoriality mistake costs you either a reassessment or trapped cash.

The firm currently keeps the French books of several branches and permanent establishments of foreign companies, American and Belgian among them: registration (apostilled and translated articles, proof of existence), accounting under the French chart of accounts, VAT returns, annual accounts and, where the director is concerned, their French-American income tax return. The situations described on this page, the branch-versus-subsidiary decision, the LLC held from France or the VAT of a company with no permanent establishment, match files actually handled, in French and in English. They remain anonymous here: professional secrecy applies to international clients as to any other.

One-off engagements follow the firm's public price list: a written consultation at EUR 450 excl. VAT for a specific question (VAT, permanent establishment, choice of structure), a written study at EUR 900 or a full situation review at EUR 1,400 excl. VAT when the file calls for an overall analysis, the scope being limited to the French side. Recurring bookkeeping for a French entity (branch or subsidiary) starts from EUR 258 excl. VAT per month and is quoted on the volume of documents, VAT and payroll; a matter spanning several countries gets a dedicated quote.

Our scope is the French side of your international activity: French accounting and tax, cross-border VAT of a French company, the French-side implantation of a foreign company, and the French taxation of an inpatriate director. We do not keep the home-country accounts, do not produce foreign tax returns (US, UK), and do not replace your local advisor: we coordinate with them.

For the bookkeeping, VAT, payroll and reporting of a subsidiary or branch that is already set up, the next step is our French CPA for foreign subsidiaries service page, which details the scope, the obligations and the fees.

We first frame the structure (branch, subsidiary, permanent establishment) and the reclassification risk, then gather the implantation documents (apostilled and translated articles, a Certificate of Good Standing under three months old, the representative's supporting documents, a domiciliation contract, EORI if needed), before setting up the French accounting, VAT and tax calendar. We apply reinforced anti-money-laundering diligence on the source of funds.

• E-invoicing, in force since 1 September 2026: a French subsidiary or branch of a foreign group must be able to receive its invoices through an accredited platform, and the group ERP does not fulfil that role on its own. The French rollout is detailed in our 2026-2027 e-invoicing guide.
• Do not confuse the absence of a permanent establishment with the absence of a VAT obligation: a foreign company registers for VAT from its first taxable transaction in France.
• A US LLC run from France is not neutral: the effective-place-of-management risk must be settled.
• Check the applicable bilateral tax treaty (elimination of double taxation) before any commitment, and remember forms 2047, 3916 and the 123 bis rule.
• The inpatriate regime is documented from the employment contract: the 30% flat election is hard to recover after the fact.

A decision specific to your situation requires reviewing your documents, your structure and the applicable treaties.

Content up to date as of 5 July 2026, reviewed by a chartered accountant. Written by Hayot Expertise (Samuel Hayot, chartered accountant and statutory auditor, Order of Chartered Accountants of Ile-de-France).