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 | email@example.com
Nathalie Cordier-Deltour | +33 (0)1 55 68 14 54 | firstname.lastname@example.org
*FIDAL is a French law firm that is independent from KPMG and its member firms.
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