Tax treaties

Treaties that have recently come into force
- France / Germany: The treaty regulating double taxation concerning estates, gifts & inheritances has come into force on April 3rd, 2009.
- France / Ethiopia: Signed on June 15th 2006 in Paris, enacted on July 17th, 2008.
- France / Libya: Signed on December 22nd 2005 in Paris, enacted on July 1st, 2008.
- France / Gabon: Signed on September, 20th, 1995 in Libreville, enacted on March 1st, 2008.

New treaties to enter into force
- France / United Kingdom: a new treaty has been signed on June 19th 2008. It should come into force during the year 2009.

Tax Information Exchange Agreement
- Jersey has signed a Tax Information Exchange Agreement with France on March 23th 2008.
- Guernsey has signed a Tax Information Exchange Agreement with France on March 24th 2008.
- The Isle of Man has signed a Tax Information Exchange Agreement with France on March 26th 2008.
- These agreements will not come into force until they are ratified by both jurisdictions.

Treaties that have been amended
- France / USA: a new amendment was signed on January 13th 2009, and has yet to be ratified by both states in order to come into force. It mainly removes the withholding tax applicable on royalties and intra group dividends under some conditions.
- France / Switzerland: an amendment has been signed on January 12th 2009 in Berne and is awaiting ratification by both states. It notably extends the provision of the Exchange of information « clause » to the information necessary in order to apply domestic law in cases involving holdings or tax fraud submitted to criminal procedures.
- France / Belgium: the amendment has been signed on December 12th 2008 and has yet to be ratified.
- France / Denmark:  the double taxation treaty was terminated by Denmark as of January 1st 2009: only domestic and EC rules apply since then.
- France / Qatar: the amendment has been signed on January 14th 2008 and has yet to be ratified.

Update of the OECD tax treaty model on July 17th 2008
The main changes concern:
- Article defining the notion of permanent establishment with respect to taxation of services
- Article  relating to allocation of profits in permanent establishments
- Articles 10 to 13 dealing with dividends and capital gains 
- Article about non discrimination
- Article providing a mutual agreement in order to solve double taxation problems.

sommaire | page suivante >