The French Council of State (Conseil d'État - Supreme Administrative Court) issued a decision on 24 February 2020 concerning the treatment of gains under the 1964 Belgium-France tax treaty derived from the alienation of shares (rights) in companies the assets of which mainly consist of French immovable property.
Article 3 (Income from Immovable Property) of the treaty provides that income from immovable property shall be taxable only in the Contracting State in which the property is situate…