According to recent reports, officials from France and South Korea have agreed to begin negotiations in 2019 for the revision of the 1979 tax treaty between the two countries. At this point, it is uncertain if the two sides intend to amend the current treaty with a protocol or replace the treaty with an entirely new text. Additional details will be published once available. Note – The 1979 treaty is a covered agreement under the BEPS MLI and would be impacted by the MLI provisions unless one or both countries decide to remove the treaty as a covered agreement.