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The New UK/France Income Tax Treaty

Annabelle Bailleul and Philippe Juilhard of CMS Bureau Francis Lefebvre discuss the changes introduced by the New UK/France Tax Treaty
A new UK/France tax treaty (the New Treaty) was signed in London by the French and UK governments on 28 January 2004 after several years of negotiation. The New Treaty will replace the present treaty between the two countries signed on 22 May 1968 (the current treaty). However certain issues will be renegotiated first which should postpone the entry into force of the amended New Treaty to 2006 or 2007. The new round of negotiations will aim at clarifying issues such as partnerships and UK-source dividends.
This article examines the main changes introduced by the New Treaty which are unlikely to be modified during the renegotiation.
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