The French Sénat adopted the laws on the amendment to the German-French Double Taxation Treaty on December 16th, 2015. From the side of the German Bundestag and Bundesrat the equivalent German law had already been passed on September 25, and 28, 2015.
The new provisions, applicable as from January 1st, 2016 are concerning especially retirees as well as artists, sportspersons and models.
Regarding the taxation of capital gains realized from the sale of shares in partnerships, civil law companies and real estate companies, the amendment extends the States’ taxation rights. As regards specifically partnerships and civil law companies, the consequences of such amendment remain still unclear. Distributions made by French real estate funds to substantial shareholders will be subject to an increased withholding tax.
Moreover, the amendment introduced specific provisions as to an exit-tax to be levied by France or Germany.