Luxembourg - France: tax agreement being renegotiated


France and Luxembourg renegotiate their agreement on the avoidance of double taxation. France’s objective in these negotiations is to allow the taxation of capital gains produced by Luxembourgish companies with no permanent setting-up in France, at the moment of the transfer of shares in real estate investment companies.

Until now these capital gains are taxable in Luxembourg and exempt in Luxembourg under certain conditions.

This amendment would have a significant impact on the real estate asset ownership structures in France implemented by non-resident investors.