A new double tax treaty beteween Luxembourg and France is not expected to gain ratification this year, but instead will be completed in 2019, leading to a suggested implementation date of 1 January 2020, according to KPMG Luxembourg.
It notes that Luxembourg's Bill 7390 is unlikely to be voted on, but instead will receive an opinion issued by the State Council as part of the next steps in the legislative process. This "is expected to occur in 2019."
If ratified by both Luxembourg and France in 2019, the treaty provisions would apply from 1 January 2020.
The French Senate approved the tax treaty on 17 December this year, and it has been sent to the French National Assembly for approval.
In linked tax news, KPMG Luxembourg also notes that the country's Bill 7333, which would ratify the MLI - developed by the OECD to integrate Beps measures into double tax treaties - is also not expected to be voted on until next year, 2019.
"After the Bill's ratification, its application per covered tax agreement (ie, double tax treaties for which the MLI will apply) will depend on the ratification by the other contracting state and on the type of tax concerned, ie, withholding tax or other taxes," KPMG noted.