2018 France-Luxembourg Income and Capital Tax Treaty Available

<p>Tax Analysts has prepared an English translation of the France-Luxembourg income and capital tax treaty signed March 20, 2018, in Paris.</p> <p>Under the treaty, dividends are taxable at a maximum rate of 15 percent. An exemption applies if the beneficial owner is a company that directly holds at least 5 percent of the capital of the payer company throughout a 365-day period that includes the date of payment of the dividends. </p> <p>If dividends are paid out of income or gains derived from immovable property by an investment vehicle that distributes most of its income annually and whose income or gains from the immovable property is exempt from tax, and the beneficial owner holds at least 10 percent of the capital of the investment vehicle, the dividends may be taxed at the domestic rate of the state in which they arise. A 15 percent rate applies if the beneficial owner holds less than 10 percent of the capital of the investment vehicle.</p> <p>Interest is taxable only in the recipient's state of residence, and royalties are subject to a 5 percent withholding rate. France generally uses the credit method to eliminate double taxation, while Luxembourg uses a combination of the credit and exemption methods.</p> <p>The treaty will enter into force upon the exchange of ratification instruments, and its provisions will generally apply from January 1 of the year following entry into force. Once in force and effective, the treaty will replace the existing agreement, which was signed in 1958 and amended by protocols signed in 1970, 2006, 2009, and 2014.</p>

<p><a href="/lr/resolve/-/27wtb" title=" ">French text</a>. <a href="/lr/resolve/-/299rq" title=" ">Prior coverage</a>.</p> <p><a href="/lr/resolve/-/1wzqj" title=" ">1958 France-Luxembourg tax treaty</a>; <a href="/lr/resolve/-/1wzqk" title=" ">1970 protocol</a>; <a href="/lr/resolve/-/1wzqr" title=" ">2006 protocol</a>; <a href="/lr/resolve/-/1wzqp" title=" ">2009 protocol</a>; <a href="/lr/resolve/-/1x309" title=" ">2014 protocol</a>.</p>

<p>Tax Analysts has prepared an English translation of the France-Luxembourg income and capital tax treaty signed March 20, 2018, in Paris.</p>

Tax Analysts has prepared an English translation of the France-Luxembourg income and capital tax treaty signed March 20, 2018, in Paris. Under the treaty, dividends are taxable at a maximum rate of 15 percent. An exemption applies if the beneficial owner is a company that directly holds at least 5 percent of the capital of the payer company throughout a 365-day period that includes the date of payment of the dividends.  If dividends are paid out of income or gains derived from immovable property by an investment vehicle that distributes most of its income annually and whose income or gains from the immovable property is exempt from tax, and the beneficial owner holds at least 10 percent of the capital of the investment vehicle, the dividends may be taxed at the domestic rate of the state in which they arise. A 15 percent rate applies if the beneficial owner holds less than 10 percent of the capital of the investment vehicle. Interest is taxable only in the recipient's state of residence, and royalties are subject to a 5 percent withholding rate. France generally uses the credit method to eliminate double taxation, while Luxembourg uses a combination of the credit and exemption methods. The treaty will enter into force upon the exchange of ratification instruments, and its provisions will generally apply from January 1 of the year following entry into force. Once in force and effective, the treaty will replace the existing agreement, which was signed in 1958 and amended by protocols signed in 1970, 2006, 2009, and 2014.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr><th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th><th>Main Country</th><th>Partner Country</th><th>Rate</th><th>Footnote 1</th><th>Footnote 2</th><th>Footnote 3</th><th>Footnote 4</th></tr> <tr> <td>Dividends</td> <td> </td> <td> </td> <td>0/15</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td> </td> <td> </td> <td>0</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td> </td> <td> </td> <td>5 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

France - Luxembourg: 2018 Income and Capital Tax Convention and Final Protocol (English Translation)

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2018 France-Luxembourg Income and Capital Tax Treaty Available