A notice from the French tax authority was published on 27 December 2023 concerning the implementation of the most favored nation (MFN) clause of the 2007 tax treaty with Kenya. According to the notice, the MFN clause was activated with the entry into force of Kenya's 2014 tax treaty with South Korea. As a result, the withholding tax rates on dividends for the purpose of the France-Kenya tax treaty are as follows: 8% if the beneficial owner is a company that directly owns at least 25% of the paying company's capital; and 10% in all other cases. The implementation of...