Treaty between Luxembourg and France – Luxembourg Administrative Court rules income of Luxembourg SA from French real estate owned by French SCI taxable in Luxembourg

On 3 May 2007, the Luxembourg Administrative Court gave its decision in case No. 22499 C on the taxability of income from real estate derived by a Luxembourg public limited company from real estate held in France through a French partnership, which did not opt to be taxed as a corporate entity in France. Details of the decision are summarized below.
(a) Facts. A L…
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