English-Speaking CPA for Expats & International Companies in Paris

France offers some of Europe's most compelling incentives for international businesses and relocating professionals: a 25% corporate tax rate, a network of 130+ bilateral tax treaties, a world-class R&D tax credit (CIR) covering 30% of qualifying expenditure, and the coveted impatriation tax regime — one of the most generous expat tax breaks on the continent. Yet navigating the French system without a specialist by your side is notoriously frustrating. The PCG accounting standard, the multi-tier social security system, the URSSAF payroll reporting requirements and the DGFiP's increasingly algorithmic audit targeting are all formidable hurdles for companies accustomed to Anglo-Saxon simplicity.

Hayot Expertise, based at 58 rue de Monceau in the 8th arrondissement of Paris, has been the trusted accounting and tax partner for English-speaking businesses and professionals for over 10 years. Our team advises directly in English — no translators, no relay — on all accounting, tax and payroll matters. Whether you are opening a French subsidiary, managing an expat workforce, structuring intragroup transactions or navigating a French tax audit, we have the expertise to protect and optimise your position.

The legal form of your French presence carries long-term tax and governance consequences. Most international groups choose the SAS (Société par Actions Simplifiée) for its Anglo-Saxon-friendly governance: a President (equivalent to CEO), a freely customisable board structure, and articles of association that can incorporate shareholders' agreement provisions such as drag-along, tag-along, vesting and pre-emption rights. Our setup services cover:

• ▸Entity type analysis: SAS vs SARL vs branch (succursale) vs representative office — a branch is not a separate legal entity and creates direct liability exposure for the foreign parent, while a representative office cannot generate revenue
• ▸Drafting bilingual articles of association and shareholders' agreements aligned with your investors' requirements
• ▸Full RCS registration: typically 8–12 business days end-to-end
• ▸Business bank account opening: we have established relationships with banks experienced in dealing with foreign-owned entities (international desks at major French banks and fintech alternatives for fast setup)
• ▸UBO (beneficial ownership) register filing — mandatory in France since 2018; non-compliance attracts significant fines
• ▸Initial tax registrations: VAT number, corporate tax instalments, CFE local business tax, monthly DSN payroll reporting

The Permanent Establishment Trap

One of the most frequently misunderstood risks for foreign companies operating in France is the permanent establishment (PE) rule. If an employee or manager based in France can legally bind the foreign company to contracts — even informally — the DGFiP may characterise the French presence as a PE and assert multiple years of unpaid corporate tax and VAT, plus penalties of up to 80%. This can happen even without a physical office. We assess your exposure and help structure your French operations to mitigate this risk from day one.

French law requires all entities incorporated in France to maintain their statutory accounts under the Plan Comptable Général (PCG), regardless of the consolidation standard applied by the parent group. There is no opt-out for IFRS preparers. This creates a dual-reporting requirement that, poorly managed, consumes significant finance team bandwidth.

Our added value is a structured PCG-to-IFRS reconciliation bridge produced at each reporting date, ready to feed directly into the group's consolidation workbooks. We handle the most significant GAAP differences methodically:

• ▸Lease accounting: IFRS 16 requires right-of-use assets and lease liabilities for virtually all leases from day one; PCG retains operating lease treatment (straight-line expense) except for finance leases identified under specific criteria — a major balance sheet difference for office-heavy businesses
• ▸Revenue recognition: IFRS 15's five-step model (performance obligations, variable consideration, principal vs agent) versus the PCG's simpler delivery/completion approach — critical for SaaS, long-term contracts and milestone billing
• ▸Financial instruments: IFRS 9 expected credit loss (ECL) provisioning versus PCG's incurred loss model — affects trade receivables and intercompany loan provisions
• ▸Employee benefits: IAS 19 requires actuarial valuation of end-of-career indemnities (indemnités de fin de carrière) — not mandatory under PCG for non-listed entities, but group reporting typically requires it
• ▸Deferred taxes: IAS 12 recognition of deferred tax assets on carried forward losses — PCG treatment is more restrictive; the reconciliation must clearly document the divergence

We produce a standardised mapping workbook updated at each close, annotated in English, directly usable by your group consolidation team.

French social charges on top of gross salary are among the highest in the OECD, typically running at 43–50% of gross payroll for employers. The system is split between base social security (URSSAF collecting health, family allowances and the main pension levy) and supplementary bodies (AGIRC-ARRCO complementary pension, mandatory company health insurance, disability/death insurance). Understanding which regime applies to each employee — and managing the monthly DSN (Nominative Social Declaration) correctly — is non-negotiable.

For internationally mobile employees, we manage:

• ▸Inter-company secondment agreements defining cost allocation between the foreign parent and the French entity
• ▸A1 certificates (EU/EEA postings) and equivalent certificates for third-country nationals, maintaining home-country social security coverage and avoiding dual contributions
• ▸Split payroll structures where salary is paid partly by the French subsidiary and partly by the foreign parent — correct reporting of both elements in the French DSN is mandatory
• ▸Tax equalisation policies: calculating the hypothetical tax, managing gross-up payments and year-end reconciliations between employer and employee
• ▸Day-count tracking for employees splitting time between France and other countries to manage dual-residence risks

The French impatriation regime (Article 155 B of the French Tax Code) is one of the most powerful expat incentives in Europe and yet remains underused because many accountants are not familiar with its mechanics. For employees and corporate officers recruited abroad who take up French tax residence, the regime provides:

• ▸50% income tax exemption on the impatriation supplement (or a flat 30% of total remuneration if the actual supplement is lower)
• ▸50% exemption on foreign-source passive income (dividends, interest, capital gains on foreign securities) for the entire 8-year eligibility period
• ▸Exemption of foreign pension and insurance contributions maintained during the posting
• ▸Potential deduction of international school fees for children

To illustrate: a VP of Engineering from the United States joining a Parisian tech company at €160,000 gross annual salary can reduce their French income tax by €22,000–€32,000 per year. Over 8 years, the cumulative saving can exceed €200,000 — a recruitment and retention advantage that smart employers advertise explicitly. We implement the regime, draft the necessary employment contract clauses and file the annual elections correctly so the benefit is never lost through a procedural error.

French subsidiaries of international groups that transact with related parties — for management services, IP licences, intercompany loans or shared functions — face growing transfer pricing scrutiny from the DGFiP. Since the 2024 Finance Act, companies with turnover exceeding €50M or intragroup transactions above €100,000 are subject to reinforced documentation requirements aligned with OECD BEPS standards.

Our transfer pricing services include:

• ▸Analysis of the French subsidiary's functional profile within the group value chain (limited risk distributor, full-fledged manufacturer, service provider, IP licensor)
• ▸Benchmarking studies to support the arm's length pricing applied to intragroup transactions (CUP, cost-plus, resale price, TNMM)
• ▸Drafting the local file (documentation de prix de transfert) including entity overview, intragroup transaction description and economic analysis
• ▸Coordination with group tax teams on the master file and CbCR (Country-by-Country Reporting) obligations
• ▸Preparation of advance pricing agreement (APA) requests with the DGFiP to lock in agreed transfer prices for 3–5 years

In over 10 years advising international clients, we have seen the same mistakes recur with costly consequences:

1. ▸Using a generalist accountant unfamiliar with international structures: the PCG-IFRS reconciliation is done poorly, group reporting deadlines are missed, and the French entity's local accounts are late or inaccurate
2. ▸Forgetting the UBO (beneficial ownership) register: a simple administrative filing that, when omitted, exposes the entity to fines of up to €7,500
3. ▸Mishandling expat payroll: split payroll without proper DSN reporting triggers URSSAF reassessments that can reach 3 years of back contributions
4. ▸Ignoring the PE risk: operating in France for 18+ months without a registered entity while a French-based employee signs contracts on your behalf is the classic recipe for a multi-year tax reassessment
5. ▸Missing the impatriation regime deadline: the option must be exercised in the year of taking up French residence — missing it permanently forfeits 8 years of tax savings

Over 10 years at 58 rue de Monceau, Paris 8, we have advised French subsidiaries of American, British, Canadian, Australian, German, Israeli and Emirati groups. Our team combines deep mastery of French accounting and tax law with the ability to communicate in fluent English on complex topics — a combination that is genuinely rare in the Parisian market. You deal directly with a chartered accountant, not a junior assistant or translated FAQ.

We are certified partners of Pennylane, the most widely-used cloud accounting platform among French startups and SMEs, enabling real-time data access in a bilingual interface, and of Silae for payroll. Your finance team can pull live data at any time, in formats you recognise.

Can I invoice French clients from abroad without a French company? Yes, provided your clients are VAT-registered French businesses (reverse charge applies) and you have no permanent establishment in France. As soon as you hire a French-based employee who can bind you contractually, PE risk materialises. We assess your situation precisely.

How long does SAS registration take? 8–15 business days from document receipt to RCS number. We manage articles of association, capital deposit, legal notice, RCS filing and all tax registrations.

My group consolidates under US GAAP — do we still need PCG books? Without exception. Every French-law entity must maintain PCG accounts. We produce the GAAP reconciliation bridge so your consolidation team receives both simultaneously.

Can you handle expat payroll with split contracts and multiple nationalities? Yes, including complex structures: split payroll, tax equalisation, multi-country day-count tracking, A1 certificates. We coordinate with your global mobility and HR teams.

📍 58 rue de Monceau, 75008 Paris | Contact us

See also: Holding tax structures | Company formation in France | Outsourced CFO services