HMRC produces synthesised version of the UK/France tax treaty

Thu 13 Jun 2019

France has deposited its ratification of the OECD’s multilateral instrument to implement tax treaty related measures to prevent base erosion and profit shifting (MLI) with the OECD. A synthesised version of the MLI and the UK/France double tax treaty is now available.

This follows a number of other synthesised texts of the MLI and double tax treaties between the UK and other territories including:

For a further discussion of the international tax issues of cross border business and the possible application of the OECD MLI, please get in touch with a member of the Mazars international tax team.

When does the MLI apply to the UK/France tax treaty?

Entry into force of the MLI for France and the UK is as follows:

1 October 2018 for United Kingdom of Great Britain and Northern Ireland and
1 January 2019 for France.

Unless stated otherwise elsewhere in synthesised text, the provisions of the MLI have effect with respect to the UK/France tax treaty as follows:

with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019;
in the United Kingdom, from 1 April 2020 for corporation tax and from 6 April 2020 for income tax and capital gains tax; and
with respect to all other taxes levied by France, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.

For further discussion of the implications of the changes, please get in touch with a member of the Mazars International tax team.

Chris Lallemand Senior Tax Manager

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