decision on taxation of capital gains derived from merger of French SCI with Luxembourg company The Court of Appeals of Luxembourg confirmed on 10 January 2006 (Case No 20307/C) an earlier decision of the Administrative Court of 20 July 2005 (Case No 19280). The Court held that capital gains derived by a Luxembourg company from the merger of a wholly-owned French SCI with another French company, in exchange for shares, are taxable in Luxembourg under Luxembourg domestic law and Art. 19(2) of the France-Luxembourg tax treaty. Details of the decision are summarized below. (a) Facts. A Luxembourg company fully owned...