The new United Kingdom-France tax treaty

The United Kingdom and France signed a new tax treaty on 19 June 2008. Most of the changes in it are due to changes in the law since the never ratified 2004 treaty, notably, the abolition of the French avoir fiscal in 2005, but the new treaty also includes the latest developments in the OECD Model, including the binding arbitration provision in the 2008 update and a topical provision dealing with real estate investment trusts. After some introductory remarks, this article discusses the treatment of partnerships under the new treaty and points out the main differences between it and the OECD Model and the 1968 UK-France treaty.