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.