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You are here: Home Finance & Business Tax New France-UK Double Taxation Treaty signed

02/10/2008New France-UK Double Taxation Treaty signed

The New France-UK Double Taxation Treaty has finally been signed. Steven Grover investigates how it might affect you.

It may have taken over four years in the making but on the 19 June 2008 a new version of the double taxation treaty between France and the UK was finally signed by the Rt Hon Alistair Darling MP, Chancellor of the Exchequer, and Mme Christine Lagarde, the French Minister for the Economy, Industry and Employment.

The new treaty is expected to enter into force some time late 2009 provided all treaty adoption procedures (i.e. parliamentary approval, ratification and exchange of diplomatic notes) are completed.

Below is a summary of some of the key elements which could affect British citizens living in or moving to France should the new draft of the treaty be ratified and become law.

Delayed Wealth tax liability
Currently UK nationals moving to France are liable for wealth tax (impot sur la fortune) on the net value of their worldwide assets, including the value of any real estate or rights in real estate outside France. However under the new agreement for the first five years after becoming a resident of France your wealth tax liability will only be based on French assets, with all other assets outside France not being taken into account. From the sixth year of residence onwards, wealth tax will then be payable on worldwide assets as normal.

If the taxpayers leave France and provided they remain outside France for at least three years, the five-year exemption applicable to non-French assets would apply once more.

It is currently unknown if this temporary exemption will only benefit individuals who move to France after the treaty enters into force, as it is a possibility that anyone who moved to France before the treaty comes into effect could still qualify for any balance of the first five years of residence when the treaty become law.

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