On 2 August 2006, the Luxembourg tax administration announced that Luxembourg and France signed in July 2006 a second protocol (the protocol) to the Luxembourg-France tax treaty on income and capital of 1 April 1958 (the treaty). The objective of the protocol is to solve the current issue of double non-taxation in the situation where a Luxembourg company owns French Real Estate without having a permanent establishment (PE) in France. The French Supreme Administration Court highlighted this "double non-taxation issue" on 18 March 1994. The Court ruled that income derived from French real estate owned by a Luxembourg company must...