French Supreme Administrative Court Finds Certain Royalties Eligible for Increased Tax Credit Under Tax Treaty with Tunisia

The French Supreme Administrative Court (Conseil d'Etat) has issued a judgment regarding the eligibility of a French taxpayer for the increased tax credit provided under Article 29(1)(d) of the 1973 tax treaty with Tunisia. Article 29(1)(d) provides that Royalties taxed in Tunisia under Article 19 (Royalties), paragraph 2(b) shall entitle the recipient to a credit equal to 20% of the gross amo…
Continue Reading