chopperoni

I am an American citizen and am thinking about the possibility of a move to FR. I would have many hurdles to jump (i.e. getting a visa), but had a question about setting up a single owner/emp corporation in France. I work in IT and typically do my work from home or travel to client sites. If I were to set up a corp in France, but all of my clients were in the UK or I did remote work for my American clients, would that be an issue? Could I feasibly offer my services to UK companies and be able to work in the UK for the week, but return to my home on the weekends in France. Would I be legally authorized to do work for a UK company being a business owner of a French company...but not an EU citizen. Or would I need to set up a company in the UK as well?

Could I keep my American company to bill my American clients--eventhough I'm doing all of my work in France (remotely from home). What if I need to return to the States for a week, for a client...the work would have been done in the US, would I have to report that income on my French taxes. I'm sure I need to speak to a French/UK accountant but just wanted to check if anyone has had any similar experiences.

TIA!

dennerlymum

sorry cant help but welcome to the forum!

cjm

Can't help with most of your post, but France requires you declare your world-wide income on its tax returns. Being domiciled in France would necessitate this. You may also have to declare income earned back in the US if you were still tax registered there. I feel sure your position (proposed position) is not unique. The internet has changed how the world can work. And, welcome to the forum.

cyrian

Hi
Getting a visa would only be the start of your problems.
You would have to struggle with the nightmare of french bureaucracy and do that in a foreign language!
Other will advise on the options on setting up a company in France but the recurring theme is that because of high taxation and social charges you have to clear a lot of turnover just to cover the costs.
I have some american friends here who rent an apartment full-time but just stay for periods of 3 months (length of visa) at a time.
They therefore don't have the taxation issues to deal with.
Why would you want to set up a business in France ( a high tax country) to service clients in the USA and the UK?
If you want to spend time in France then why don't you follow the example given above and come as a visitor and if you use the internet when you are here then good and well.
Whatever you do - do not become tax resident in France.

Please read the current post by sushiholic.

Good luck

Domino

if the money is really good - have you thought about Monaco ?

there are many Brits who reside there, have Uk based co's, do all their work there, catching the first plane out in the morning and the last plane back at night.
Sir Philip Green and the Candy brothers come to mind.

there have been press reports about a tube system running along side the Chunnel allowing an alternative mode of transport for French(wo)men to travel to the Uk on a daily basis.

think you need to talk to an international accountant about a company in each country to handle billing in that country. this will keep you from the direct income, then sell your services to the company, keeping your income(s) at the correct level to maximise income whilst minimising taxation.

know little of the French tax system but the Uk has a Dual Taxation agreement with a number of countries so tax is only paid once - so long as it is paid somewhere.

dmu

Hi, when I was working for myself as an Sàrl (limited liability company), I paid more than 50% of my salary as social charges, plus insurance, overheads, etc... which have to be paid, whatever. Which often meant that some months were lean. In addition, I paid Income Tax on the declared salary, not what I actually took home. Conclusion, not the recommended route, although you have healthcare coverage and end up with a good pension!
You should consult an Expert-Comptable who'd advise you what sort of company to set up in France, if any.

chopperoni

Thank you for the replies and the warm welcome .

My DH and I are just looking for a way to move to FR and be legal. The 50% tax definitely bites but I don't think we would have any problems clearing the turnover. I have a current client based out of the UK who I've been working with for the last 1 1/2 years and checking out the UK job boards there seems to be a high demand for my IT skills. My skill-set seems to be in demand in FR as well, but my language skills (lack of) would make it difficult. My old employer was a French company, so I could possibly explore that route...but even with the 50% tax, I would probably still make more going the consulting route.

The Monaco idea is an interesting one. I've never been there. I'll definitely look into that.

Renting the apartment but only staying for 3 month chunks would not work for us as we have a little one who will need to go to school.

Looks like the US has a tax agreement with Fr, so I would not be taxed twice.
A lot of my US work would be done remotely at my house...so if I was living in France it would be done in France, even though it's for a US company. It would be easier if I could keep my US company for billing and just report the income on my French taxes as opposed to have to have the US companies try to pay me for my work to a French company.

If anyone has any other ideas/thoughts, please keep them coming. Also, if anyone can recommend a good Intl Tax Accountant please let me know

TinaBee

In general, AFAIK, if you do the work in France then you must pay your insurances and taxes in France, irrespective of the location of your clients. There are a few websites that can help with starting a business in France - if you google "start a business in france" you will find several.

Also, it may be possible to start working in France using a "portage salariale" company - this is an expensive way to operate in the long term, but may be an option to get you started and an easy way into the French employment system, giving you some breathing space in order to decide on the most appropriate business structure.

This company offers an English-speaking portage service and their website explains how it works
http://www.freelanceinfrance.com/

cyrian

In addition to income tax you have social security charges and top-up insurance cover to pay.
Then you have wealth tax which is levied on your world-wide assets which would include any assets or property you have in the USA.
If you are tax resident in France then you have to fill an annual tax form in France where you declare any income and tax paid in other countries. If there is a tax agreement then you possibly don't have to pay any more tax.
Therefore, it is possible to invoice clients and pay tax in the USA or the UK as long as you declare it all in your french tax return.
Your situation is a complicated one and you need to get expert advice as to the best route for you.
Sorry, I can't suggest suitable accountants but there are loads of adverts in magazines or you could Google it.
Can your bank help or advise?
Good luck with your homework

dmu

If you mean the 50% which I mentioned, it wasn't income tax, but Social Contributions. For example, if you give yourself a monthly salary of for example 3000€, you pay at least 1500€ for Social Security, Pension, etc.. Contributions, not to mention professional taxes, professional insurance, overheads... You'd have to bill (and be paid for) say at least 2000€ before you'd receive any salary. This was my experience as an Sàrl (on a much lower salary!) and I wouldn't recommend it!

Tweedpipe

As a reminder for the wealth tax - if your world wide assets exceed 800,000€ one is liable for the tax at a rate of 0.55% up to 1.310.000€.
Assets above this latter sum are taxable at 0.75% and upwards on a sliding scale.
A revision to this is proposed for 2012 as shown HERE.

Ka Ora!

Welcome to the Forum, If you get any issues give me a shout.

Domino

with all that taxation why isn't France an empty country ? ?

cyrian

Perhaps because there are ways to reduce your tax bill like invest in rental properties or not quite remember to declare everything.
The tax tends to begin at lower rates % than in the UK and increases in stages to the higher levels.
The french stay here because they are french but lots of the younger ones move to the UK esp London where jobs in the City and in financial services and in IT are still plentiful with better chance of promotion than in France.
The brits just like the pace of life; the food; the wine and the weather.
The downside is the taxes and of course the french