The 2014 protocol to the 1958 income and capital tax treaty between France and Luxembourg will enter into force on 1 February 2016. The protocol, signed 5 September 2014, is the fourth to amend the treaty.
The protocol adds a fourth paragraph to Article 3 of the treaty that includes the provision that gains from the alienation of shares or other rights in a company, trust or any other institution or entity will be taxable in a Contracting State if:
- 50% or more the entity's asset or property…