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France Ratifies Pending Protocol to Tax Treaty with Luxembourg

21 February 2025

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Treaty Development

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France-Luxembourg

France has published Law No. 2025-139 of 17 February 2025 in the Official Gazette, which provides for the ratification of the pending protocol to the 2018 income and capital tax treaty with Luxembourg. 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 treaty. It will enter into force...