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Tax and Chat : Impact of the fourth amendment to the France-Luxemburg tax treaty



Tax and Chat : Impact of the fourth amendment to the France-Luxemburg tax treaty
How will the long awaited change of the France-Luxembourg tax treaty affect present and future real estate structuring?

With the recent signature of the long dreaded fourth amendment to the tax treaty between France and Luxembourg, real estate practitioners are getting increasingly worried that the said amendment will impact both existing portfolios and futures operations.

Our firm wishes to provide you with a straight-to-the-point, business-minded and efficient online presentation of the key aspects of the coming amendment.

A webcast, along with an interactive chat, will be hosted by the real estate team of Arsene with the advice of Taxand Luxembourg (Atoz) on September 18th, 2014 (9:30-10:30 am) during which the following critical points will be addressed:
 
Limited yet critical change to the tax treaty
  • Modification of the allocation rules of the taxation of capital gains on real estate companies
  • No anticipated impact on the notion of residence or the taxation of passive income.
 
Entry into force as of 2015 at the earliest
  • Ratification and notification by both countries has yet to happen.
  • The French Tax Administration is aiming for a completion of the process by year end.
  • Expected impact on disposal occurring as from January 1st, 2015.
 
Prospective, what’s next?
  • Course of action for existing portfolios: what solutions are still available?
  • Course of action for future transactions: how to structure your upcoming operations?
 
Thank you for confirming your registration as soon as possible by completing the registration form.
You will then receive all necessary information.

For further information please contact Mélissande Gallet by mail at melissande.gallet@arsene-taxand.com or by phone at +33 (0) 1 70 39 54 97

 
Tax and Chat : Impact of the fourth amendment to the France-Luxemburg tax treaty
11 Septembre 2014
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With the recent signature of the long dreaded fourth amendment to the tax treaty between France and Luxembourg, real estate practitioners are getting increasingly worried that the said amendment will impact both existing portfolios and futures operations.

Our firm wishes to provide you with a straight-to-the-point, business-minded and efficient online presentation of the key aspects of the coming amendment.

A webcast, along with an interactive chat, will be hosted by the real estate team of Arsene with the advice of Taxand Luxembourg (Atoz) on September 18th, 2014 (9:30-10:30 am) during which the following critical points will be addressed:
 
Limited yet critical change to the tax treaty
  • Modification of the allocation rules of the taxation of capital gains on real estate companies
  • No anticipated impact on the notion of residence or the taxation of passive income.
 
Entry into force as of 2015 at the earliest
  • Ratification and notification by both countries has yet to happen.
  • The French Tax Administration is aiming for a completion of the process by year end.
  • Expected impact on disposal occurring as from January 1st, 2015.
 
Prospective, what’s next?
  • Course of action for existing portfolios: what solutions are still available?
  • Course of action for future transactions: how to structure your upcoming operations?
 
Thank you for confirming your registration as soon as possible by completing the registration form.
You will then receive all necessary information.

For further information please contact Mélissande Gallet by mail at melissande.gallet@arsene-taxand.com or by phone at +33 (0) 1 70 39 54 97

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How will the long awaited change of the France-Luxembourg tax treaty affect present and future real estate structuring?

With the recent signature of the long dreaded fourth amendment to the tax treaty between France and Luxembourg, real estate practitioners are getting increasingly worried that the said amendment will impact both existing portfolios and futures operations.

Our firm wishes to provide you with a straight-to-the-point, business-minded and efficient online presentation of the key aspects of the coming amendment.

A webcast, along with an interactive chat, will be hosted by the real estate team of Arsene with the advice of Taxand Luxembourg (Atoz) on September 18th, 2014 (9:30-10:30 am) during which the following critical points will be addressed:
 
Limited yet critical change to the tax treaty
  • Modification of the allocation rules of the taxation of capital gains on real estate companies
  • No anticipated impact on the notion of residence or the taxation of passive income.
 
Entry into force as of 2015 at the earliest
  • Ratification and notification by both countries has yet to happen.
  • The French Tax Administration is aiming for a completion of the process by year end.
  • Expected impact on disposal occurring as from January 1st, 2015.
 
Prospective, what’s next?
  • Course of action for existing portfolios: what solutions are still available?
  • Course of action for future transactions: how to structure your upcoming operations?
 
Thank you for confirming your registration as soon as possible by completing the registration form.
You will then receive all necessary information.

For further information please contact Mélissande Gallet by mail at melissande.gallet@arsene-taxand.com or by phone at +33 (0) 1 70 39 54 97


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