us france double taxation treaty


How does the convention prevent international double taxation?

The Convention confirms that the country of residence will avoid international doubletaxation by providing relief for the tax imposed by the source country. It also provides foradministrative cooperation between the tax authorities of the two countries in applying theConvention and the taxes covered by the Convention.

Do US companies pay taxes in France?

in the case of a United States company owning at least 10 percent ofthe voting power of a company that is a resident of France and from which theUnited States company receives dividends, the French income tax paid by or onbehalf of the distributing corporation with respect to the profits out of which thedividends are paid.

What are the benefits of a bilateral tax treaty?

It also provides foradministrative cooperation between the tax authorities of the two countries in applying theConvention and the taxes covered by the Convention. The benefits of the Convention are limitedto qualified residents of the two countries.

What if a partnership is not exempt from French tax?

(d) If, for any taxable period, a partnership of which an individual member is aresident of France so elects, for United States tax purposes, any income which solely byreason of paragraph 4 of Article 14 is not exempt from French tax under this Article shallbe considered income from sources within France.

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