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Tax Treaty Policies CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GENERAL EFFECTIVE DATE UNDER ARTICLE 33: 1 JANUARY 1996 TABLE OF ARTICLES Article 1---------------------------------Personal Scope Article 2---------------------------------Taxes Covered Article 3---------------------------------General Definitions Article 4---------------------------------Resident Article 5---------------------------------Permanent Establishment Article 6---------------------------------Income From Real Property Article 7---------------------------------Business Profits Article 8---------------------------------Shipping and Air Transport Article 9---------------------------------Associated Enterprises Article 10--------------------------------Dividends Article 11--------------------------------Interest Article 12--------------------------------Royalties Article 13--------------------------------Capital Gains Article 14--------------------------------Independent Personal Services Article 15--------------------------------Dependent Personal Services Article 16--------------------------------Directors' Fees Article 17--------------------------------Artistes and Sportsmen Article 18--------------------------------Pensions Article 19--------------------------------Public Remuneration Article 20--------------------------------Teachers and Researchers Article 21--------------------------------Students and Trainees Article 22--------------------------------Other Income Article 23--------------------------------Capital Article 24--------------------------------Relief From Double Taxation Article 25--------------------------------Non-Discrimination Article 26--------------------------------Mutual Agreement Procedure Article 27--------------------------------Exchange of Information Article 28--------------------------------Assistance in Collection Article 29--------------------------------Miscellaneous Provisions Article 30--------------------------------Limitation on Benefits of the Convention Article 31--------------------------------Diplomatic and Consular Officers Article 32--------------------------------Provisions for Implementation Article 33--------------------------------Entry Into Force Article 34--------------------------------Termination Letter of Submittal---------------------of 9 September, 1994 Letter of Transmittal-------------------of 19 September, 1994 Notes of Exchange---------------------of 31 August, 1994 The “Saving Clause”-------------------Paragraph 2 of Article 29 MESSAGE FROM THE PRESIDENT OF THE UNITED STATES TRANSMITTING CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL SIGNED AT PARIS ON AUGUST 31,1994, TOGETHER WITH TWO RELATED EXCHANGES OF NOTES LETTER OF SUBMITTAL DEPARTMENT OF STATE, Washington, September 9, 1994. The PRESIDENT, The White House. THE PRESIDENT: I have the honor to submit to you, with a view to its transmission to the Senate for advice and consent to ratification, the Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed at Paris on August 31, 1994, together with two related exchanges of notes signed on the same date. The new Convention will replace the existing income tax convention between the United States and France, which was signed in 1967 and amended by Protocols signed in 1970, 1978, 1984, and 1988, and the side letters relating thereto. The new Convention maintains many provisions of the existing convention; but it also provides certain additional benefits, and it updates the text to reflect current tax treaty policies. Like all U.S. income tax conventions, this Convention provides rules specifying when income that arises in one of the countries and is derived by residents of the other country may be taxed by the country in which the income arises (the “source country”). Rules are provided for each category of income, such as business profits, investment income, and personal service income. The Convention confirms that the country of residence will avoid international double taxation by providing relief for the tax imposed by the source country. It also provides for administrative cooperation between the tax authorities of the two countries in applying the Convention and the taxes covered by the Convention. The benefits of the Convention are limited to qualified residents of the two countries. The new Convention confirms that residents of each country include tax-exempt organizations created for charitable and other not-for-profit purposes or for purposes of providing pension benefits, and extends to them part of the dividend tax credit that France provides in the Convention to other U.S. portfolio investors. It also addresses the treatment of dividends paid by regulated investment companies and real estate investment trusts, bringing those provisions into line with current U.S. treaty policy. The new Convention clarifies the scope of the exemption at source of copyright royalties. An important improvement in the new Convention is the modernization of the limitation on benefits provisions, designed to ensure that the benefits of the Convention are enjoyed only by those persons intended to derive such benefits. The compliance aspects of the Convention are also strengthened by bringing up to date the provisions concerning associated enterprises and the exchange of tax information. The new Convention preserves the special French tax benefits for U.S. citizens residing in France and for French residents who are partners of U.S. partnerships. The exchanges of diplomatic notes accompany the Convention and state the understandings of the two delegations with respect to the application of the Convention in specified cases. The United States and France will notify each other when their respective constitutional and statutory requirements for the entry into force of the Convention have been satisfied. The Convention will enter into force on the date of receipt of the later of those notifications. The provisions concerning taxes on dividends, interests, and royalties and the U.S. excise tax on insurance premiums paid to foreign insurers will take effect on the first day of the second month following the entry into force. The provisions concerning other taxes generally will take effect for taxable years or taxable events occurring on or after January 1 of the year following the entry into force. However, certain provisions concerning the availability of the French dividend tax credit and the application of the copyright royalty exemption will apply for dividends and royalties paid or credited on or after January 1, 1991. The 1967 convention and the related exchanges of letters will cease to have effect as of the date on which the provisions of this Convention become effective. A technical memorandum explaining in detail the provisions of the Convention will be prepared by the Department of Treasury and will be submitted separately to the Senate Committee on Foreign Relations. The Department of the Treasury and the Department of State cooperated in the negotiation of the convention. It has the full approval of both Departments. Respectfully submitted, WARREN CHRISTOPHER. LETTER OF TRANSMITTAL THE WHITE HOUSE, September 19, 1994. To the Senate of the United States: I transmit herewith for Senate advice and consent to ratification the Convention Between the Government of the United States of America and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed at Paris on August 31, 1994, together with two related exchanges of notes. Also transmitted for the information of the Senate is the report of the Department of State with respect to the Convention. The Convention replaces the 1967 income tax convention between the United States of America and the French Republic and the related protocols and exchanges of notes. The new Convention more accurately reflects current income tax treaty policies of the two countries. I recommend that the Senate give early and favorable consideration to the Convention and related exchanges of notes and give its advice and consent to ratification. WILLIAM J. CLINTON. CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL The Government of the United States of America and the Government of the French Republic, desiring to conclude a new convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, have agreed as follows: ARTICLE 1 Personal Scope This Convention shall apply only to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. ARTICLE 2 Taxes Covered 1. The taxes which are the subject of this Convention are: (a) in the case of the United States: (i) the Federal income taxes imposed by the Internal Revenue Code (but excluding social security taxes); and (ii) the
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