The 2015 protocol to the 1959 income and capital tax treaty between France and Germany entered into force on 24 December 2015. The protocol, signed 31 March 2015, is the fourth to amend the treaty. Key amendments are summarized as follows.
Persons Covered
A new paragraph is added to Article 1, specifying that the treaty only applies to persons resident in one or both of the Contracting States, and the meaning of the term "resident of a Contracting State" is amended.
Capital Gains
Articl…