New protocol to the France-United States tax treaty

On 13 January 2009, France and the United States signed a protocol amending the 1994 France-United States double taxation treaty as amended by a protocol in 2004. The new protocol is supplemented by a Memorandum of Understanding that sets out the details of the arbitration proceedings provided in Art. 26 (mutual agreement procedure) of the treaty. This article discusses the more important changes made by the new protocol and the new arbitration proceedings, which may be mandatory.