Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And France : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-14-88

Cover Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And France : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-14-88
Explanation of Proposed Protocol to the Income Tax Treaty Between the United States And France : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On August 9, 1988 Jcs-14-88
United States. Congress. Joint Committee On Taxation
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Like the U( model treaty, the proposed protocol defines "dividends" as incor^ from shares or other rights which participate in profits and whi| are not debt claims. To conform with French law, the term also i eludes income from "jouissance" shares or "jouissance" righ mining shares, or founders shares which participate in profits ai which are not debt claims. Dividends also include income fro other corporate rights which is subjected to the same tax treatme by the country in which the distribut...ing corporation is resident income from shares. Under this provision, each country may app its rules for determining when a payment by a resident company on a debt obligation or an equity interest.
Article V. Interest The existing treaty provides that when a person paying inter^ has a permanent establishment or fixed base in a treaty countrl in connection with which the indebtedness giving rise to such int^ est was incurred, and such interest is borne by such permanent € tabhshment or fixed base, then the interest shall be deemed arise in the country in which the permanent establishment or fixe u ?i ^1 situated.


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