France/Luxembourg protocol taxing indirect real estate transfers to enter into effect in 2017

A protocol to the Luxembourg/France tax treaty, signed September 15, 2014, has been ratified by both jurisdictions and will enter effect on January 1, 2017, according to the Luxembourg Ministry of Finance.

The agreement, which is the fourth amendment to the 1958 Luxembourg/France double tax agreement, permits source county taxation of gains from the sales of shares of companies that primarily invest in immovable property, such as real estate.

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