On 5 September 2014, officials of France and Luxembourg signed a protocol to the 1958 income tax treaty between the two countries. The protocol is the fourth to amend the treaty.
The protocol adds the provision that when a company, trust or any other institution directly or indirectly derives more than 50% of its value from immovable property located in a Contracting State, gains on the alienation or disposition of shares or other rights in such company, trust or any other institution will b…