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France Confirms Activation of MFN Clause for Interest and Royalties in Tax Treaty with Latvia

21 October 2024

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Treaty Development

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France-Latvia

A notice from the French tax authority was published on 16 October 2024 concerning the implementation of the most favored nation (MFN) clause of the 1997 tax treaty with Latvia. According to the notice, the MFN clause was activated with the entry into force of Latvia's 2017 tax treaty with Japan. As a result, for the purpose of the France-Latvia tax treaty: Interest paid from a Contracting State on loans granted by a credit institution and beneficially owned by a resident of the other Contracting State are taxed only in the other Contracting State (i.e., exempt from withholding tax); Royalties...