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French Senate Approves Pending Protocol to Tax Treaty with Luxembourg

18 March 2024

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Treaty Development

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France-Luxembourg

On 14 March 2024, the French Senate (upper house of parliament) approved the law 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 and will enter into force once the...