On 5 September 2014, officials of France and Luxembourg signed a protocol to the 1958 income tax treaty between the two countries. The protocol is the fourth to amend the treaty. The protocol adds the provision that when a company, trust or any other institution directly or indirectly derives more than 50% of its value from immovable property located in a Contracting State, gains on the alienation or disposition of shares or other rights in such company, trust or any other institution will be subject to tax exclusively in that State. However, the provision does not apply for dispositions that...