UK/France Double Tax Treaty Enters Into Force

by Jason Gorringe, Tax-News.com, London

22 December 2009

UK tax authority HM Revenue and Customs has announced that the double taxation convention between the UK and France, signed on June 19, 2008, entered into force on December 18, 2009.

The new agreement, which was signed in London by UK Chancellor of the Exchequer Alistair Darling and French Finance Minister Christine Lagarde, replaces the one originally signed in January 2004. Changes to the tax systems in both countries meant that the previous convention was not taken forward and was superseded by the text of the agreement signed in 2008.

The new convention replaces the original convention signed in 1968 and applies to persons who are residents of one or both of the contracting states.

In the case of the UK, the taxes covered by the convention include the income tax, the corporation tax and the capital gains tax.

In the case of France, the convention applies to all taxes imposed on behalf of the state or of its local authorities, irrespective of the manner in which they are levied on total income or on elements of income, including gains from the alienation of movable and immovable property, taxes on the total amount of wages or salaries paid by enterprises, as well as taxes on capital appreciation. In particular, these taxes include the income tax, the corporate tax, the social contribution on corporate tax, the tax on salaries, the "contributions sociales généralisées," and the "contributions pour le remboursement de la dette sociale."

The convention also contains an exchange of information article.

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