New Tax Treaty Between France and Luxembourg: French Tax Implications for Investors
/France and Luxembourg signed a new double tax treaty on income and capital in late March. Ratification by the end of the year is anticipated. The new treaty reflects the current post-B.E.P.S. environment. Among other things, the residence definition is tightened, the test for the existence of a permanent establishment is loosened, real estate funds face higher withholding tax, a credit method is adopted to avoid double taxation. Christophe Jolk, Attorney at Law, Paris, explains the implications for investors.
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