Luxembourg and France amend double tax treaty to permit source country taxation of indirect real estate transfers

Luxembourg and France on Sept. 5 signed the 4th amendment to their 1958 double tax agreement, providing for source country taxation of gains from the sale of shares of companies that primarily invest in immovable property, such as real estate.  Text of the amendment (in French),  release (in French). For analysis, see Arendt & Medernach, Loyens & Loeff, Baker & McKenzie