The Administrative Court of Montreuil, France recently published Case Law (Jurisprudence) Letter No. 16 of January 2025, which includes a selection of decisions of interest from the second half of 2024. One notable decision concerns the taxation of royalty income received by a French company for the use of or the right to use industrial, commercial, or scientific equipment (equipment royalties) under the 2013 France-China tax treaty, which was issued on 20 June 2024. Paragraph 6 of the final protocol signed with the treaty provides that equipment royalties shall be subject to tax on 60% of the gross amount of...