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Amending Protocol to Tax Treaty Between France and Luxembourg has Entered Into Force

30 April 2025

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Treaty Development

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France-Luxembourg

France has published Decree No. 2025-382 of 28 April 2025 in the Official Gazette, which includes that the amending protocol to the 2018 income and capital tax treaty between France and Luxembourg entered into force on 4 March 2025. The protocol, signed 7 November 2022, provides for an increase in the tolerance (time) threshold for cross-border workers from 29 days to 34 days under the treaty. As such, cross-border workers who reside in France and work in Luxembourg can work 34 days outside Luxembourg without being taxable in France (and vice versa). The protocol is the second to amend the...