PDF u.s. france tax treaty technical explanation 2009 PDF

Where can I find the tax treaty documents?

The complete texts of the following tax treaty documents are available in Adobe PDF format. If you have problems opening the pdf document or viewing pages, download the latest version of Adobe Acrobat Reader. For further information on tax treaties refer also to the Treasury Department's Tax Treaty Documents page.

Is the income of a permanent establishment exempt from French tax?

Under a current French income tax treaty with the host jurisdiction of the permanent establishment, the income of the permanent establishment is exempt from French tax (alternatively, France may choose to exempt the income of the permanent establishment from French income tax by statute).

Are dividends taxable in France?

In the latter case, the dividends are taxable by France or the United States under Article 7 (Business Profits) or 14 (Independent Personal Services). Thus, a Contracting State may not impose a "secondary" withholding tax on dividends paid by a nonresident company out of earnings and profits from that Contracting State. 14

Can a company qualify for treaty benefits under Article 10(3)(b)?

For purpose of Article 10(3)(b), it is not sufficient for a company to qualify for treaty benefits generally under the active trade or business test or the ownership-base erosion test unless it qualifies for treaty benefits under both.