On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate.
Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating the right to tax capital gains from the disposal of shares in predominantly real estate entities exclusively to the State where the real estate assets are located.
Please see full publication below for more information.