The US and France have signed a protocol that on ratification will update the current US-France income tax treaty. The January 13 protocol will make several changes to the existing agreement including the elimination of source-country taxation of certain parent-subsidiary dividends, ending source-country taxation of cross-border royalty payments and strengthening the limitation of benefits provision. The protocol also provides for mandatory arbitration of certain cases that cannot be resolved by the competent authorities and updates the rules for exchange of information between the tax authorities.
January 26 2009