On 31 March 2015, officials from France and Germany signed a protocol to the 1959 income and capital tax treaty between the two countries. The protocol is the fourth to amend the treaty. Key amendments are summarized as follows: Persons Covered A sentence is added to Article 1 of the treaty, specifying that the treaty only applies to persons resident in one or both of the Contracting States. Capital Gains Article 7 of the treaty, which covers certain capital gains, is rewritten in line with Article 13 of the OECD Model, including the provisions that gains from the alienation of...