On 24 November 2006, Luxembourg and France signed a second protocol to the Luxembourg-France tax treaty on income and capital of 1 April 1958. The provisions of the protocol authorize the state where immovable property is situated to tax profits, income and gains from the exploitation and transfer of immovable property, without distinction whether the owner of the immovable property is an individual, a company or a transparent entity and regardless of whether or not the immovable property is attributable to a permanent establishment in the situs country.