The protocol updates the 1990 France–Sweden Income and capital tax treaty with OECD BEPS standards. 

France’s Council of Ministers approved the amending protocol to the 1990 France–Sweden Income and Capital Tax Treaty on 11 July 2025.

This protocol, which updates the treaty in line with OECD BEPS standards, includes revisions to the preamble, Article 25 on the Mutual Agreement Procedure, and introduces a new Article 28A on Entitlement to Benefits.

Following Council approval, the protocol has been submitted to the French Senate for ratification.

It will enter into force 30 days after the exchange of ratification instruments and apply from 1 January of the following year.