TAX NEWS - January 2010

France - United States Tax Treaty

The 2009 protocol entered into force in December 2009, and applies retroactively to withholding taxes paid or credited on or after 1 January 2009. With respect to other income or capital taxes, the protocol generally applies for taxable periods beginning on or after 1 January 2010. The protocol includes a 0% tax rate on certain qualifying (i.e. intercompany) dividends and a 0% tax rate on royalties.