The official ceremony for the signing of the multilateral convention to implement tax treaty measures to prevent BEPS (the “multilateral instrument” or MLI) took place on 7 June 2017 in Paris. France was one of 67 countries signatories (representing 68 jurisdictions), being noted that eight other jurisdictions have expressed their intention to sign the MLI.
At the time of signing or, at the latest, when the instrument of ratification is deposited, each signatory country must provide the OECD with a list of the bilateral treaties modified by the multilateral instrument as well as the list of options and reservations made with respect to the various provisions of the convention.
Regarding France, 88 tax treaties are covered (out of a total of 125 treaties) by the MLI, including those concluded with major business partners—e.g., Germany, the Netherlands and the United Kingdom. As did several other countries, France also included the treaty concluded with the United States even though the United States was not expected to sign the MLI.
The statements made by France, to date, reveal that:
These positions taken by France are expected to be confirmed at the time of depositing the instrument ratifying the MLI.
For more information, contact a tax professional at FIDAL* in Paris or the French KPMG Tax center in New York:
Patrick Seroin | +1 (212) 954-2523 | firstname.lastname@example.org
Nathalie Cordier-Deltour | +33 (0)1 55 68 14 54 | email@example.com
*FIDAL is a French law firm that is independent from KPMG and its member firms.
© 2019 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.