MFN clause of the protocol to the Income and Capital Tax Treaty between France and Chile of 2004 activated

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The Tax Administration of France updated the guidance on 4 November 2016 about activation of the most favoured nation (MFN) clauses concluded by France on certain tax treaties.

Accordingly, the MFN clause in paragraph 6 of the protocol to the Chile – France Income and Capital Tax Treaty (2004) was activated by the Australia – Chile Income Tax Treaty (2010 and as a result the withholding tax rate applicable to interest referred to in article 11(2)(b) of the Chile-France treaty is lowered by a rate of 10%.

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