A decision of the Administrative Court of Appeal of Paris was published on 30 June 2020 concerning whether a company benefiting from export incentives in Tunisia may qualify as a resident of Tunisia for the purpose of the 1973 France-Tunisia tax treaty and qualify for treaty benefits.
The case involved a Tunisian export company that benefited from an incentive allowing it to deduct all foreign-source profits from their taxable result for a 10-year period. In 2013 and 2014, payments were mad…