France - Significant Amendments to the France–United States Tax Treaty
- B. Gouthière
- European Taxation, 2010 (Volume 50), No 5
- 29 March 2010
In this article, the author provides a comprehensive overview of the amendments to the France–United States tax treaty, introduced by the 2009 Protocol, and analyses their practical implications for taxpayers. The changes concern, particularly, the application of the treaty to tax-exempt entities, the treatment of partnerships, exemptions from withholding tax on intra-group dividends and on royalties, avoidance of double taxation, introduction of a mandatory arbitration provision and limitation on treaty benefits.