Double Taxation Agreement Between Germany And France

In many cases, the wording of the provisions is not easy to understand and complex. There are many exceptions. Both for individuals who earn income abroad (for example. B dividends or even wages) than for companies that are setting up internationally – or planning – it is worth taking a closer look at double taxation agreements. Germany signed its first double taxation agreement with France in 1959. The agreement was ratified in 1961 and implemented in 1962. Since then, the Convention has undergone several amendments and has been amended several times, with the last amendment added in 2003. However, the two States Parties have added other provisions to their double taxation agreement, one relating to the taxation of border workers in Germany and France and the other relating to the taxation of estates, estates and property. Earlier this year, the double taxation convention between Germany and France was revised and amended. However, it has not yet been implemented in both countries.

Germany has signed double taxation agreements with (z.B.): on 31 March 2015, the finance ministers of France and Germany signed an amendment („amendment“) to the double taxation agreement between France and Germany on 21 July 1959 („FR/GER Treaty“), amended on 9 June 1969; September 28, 1989; December 20, 2001. Agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income and capital taxes The amendment introduces a new paragraph 10 relating to Article 9 of the FR/GER Treaty, which provides for dividend distributions by real estate investment companies (Listed Real Estate Investment Company, „SIIC“) and real estate funds (Real Estate Collective Investment Organization, OPCI) for France and G-REIT for Germany. This new paragraph uses a wording similar to that, for example, of the 2008 double taxation agreement between France and the United Kingdom: Dividends paid on income or profits of real estate assets are refused if (i) the real estate investment vehicle distributing (a) distributes the most much of this income or profits each year and b) the benefits of a tax exemption for these products or profits and (ii) the economic beneficiary of these dividends directly or indirectly holds 10 or more of the capital of the real estate investment distributing.