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Executive summary
On 20 March 2018, the new Luxembourg-France Income Tax Treaty (New Treaty) and a new protocol were signed by the Governments of France and Luxembourg, replacing the current double tax treaty signed on 1 April 1958 (Current Treaty). The New Treaty is based on the 2017 Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (MTC), and contains significant changes including provisions to meet OECD standards, the definition of tax residency, and the withholding tax treatment of dividend distributions.
The New Treaty is likely to significantly impact tax structuring of French real estate investments via Luxembourg but will also require the review of certain existing or prospective structures...
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