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 article 5 of the protocol to the Bolivia – France Income and Capital Tax Treaty (1994) was activated by the Bolivia – Spain Income and Capital Tax Treaty (1997) and this modified the rules applicable to certain dividends, interest and royalties.
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