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.
As a result, the MFN clause in article II of the protocol to the Egypt – France Income and Capital Tax Treaty (1980) (as amended through 1999) was activated by the France – Uzbekistan Income and Capital Tax Treaty (1996) and the Bahrain – Egypt Income Tax Treaty (1997). Therefore, remuneration related to contracts for studies and consultancy services paid to a resident of Egypt or France will no longer be subject to a withholding tax.
