The French Supreme Administrative Court (Conseil d'Etat) has issued a judgment regarding the eligibility of a French taxpayer for the increased tax credit provided under Article 29(1)(d) of the 1973 tax treaty with Tunisia. Article 29(1)(d) provides that Royalties taxed in Tunisia under Article 19 (Royalties), paragraph 2(b) shall entitle the recipient to a credit equal to 20% of the gross amount of the royalties. Paragraph 2(b) concerns royalties from the grant of licenses for the use of patents, designs and models, plans, secret formulae, or processes, which are subject to a withholding tax rate of 15% under the treaty....