On 31 March 2015, officials from France and Germany signed a protocol to the 1959 income and capital tax treaty between the two countries. The protocol is the fourth to amend the treaty. Key amendments are summarized as follows:
Persons Covered
A sentence is added to Article 1 of the treaty, specifying that the treaty only applies to persons resident in one or both of the Contracting States.
Capital Gains
Article 7 of the treaty, which covers certain capital gains, is rewritten in line…