Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 8
BRANCH PROFITS TAX
Companies resident in the Federal Republic which maintain a permanent establishment in France shall not be liable to the tax on distributions (impôt de distribution) referred to in Article 115 quinquies of the General Tax Code.