22
Mar
By Loyens & Loeff
On 20 March 2018, France and Luxembourg signed a new double tax treaty (the “Treaty”) based on the latest version of the OECD model convention and implementing BEPS minimum standards. The Treaty will facilitate various types of investments in France through Luxembourg funds; changes to taxation of certain real estate investment vehicles may, however, have an impact on some existing structures and require a restructuring.
The Treaty reduces the minimum shareholding threshold to 5% (with a minimum...