Question 5948 — income tax

Summary

Mr. Pieyre-Alexandre Anglade draws the attention of the Minister of the Economy, Finance and Industrial and Digital Sovereignty to the problem of double taxation of income from French real estate companies (SCI) held by persons residing for tax purposes in Belgium. Currently, this income is taxed in France as property income and in Belgium as dividends, due to a divergence of tax qualification between the two countries on this type of income. For comparison, the tax convention between France and Luxembourg distinguishes transparent companies from opaque companies and provides that partners of partnerships considered transparent can take advantage of the provisions of the convention to avoid double taxation. Likewise, the tax convention between France and Switzerland provides for specific measures to eliminate potential double taxation and the recent judgment of the Swiss federal court, although recognizing the non-translucent nature of French SCIs in Swiss law, goes in line with the objective of the convention and provides the tools to avoid any double taxation. He therefore asks him if the Government plans to enter into negotiations with the Belgian authorities in order to revise the tax convention Franco-Belgian to eliminate double taxation of income from French SCIs held by Belgian residents; these discussions could be held during those to be planned for the introduction of a teleworking quota in this same tax convention.

Machine translation from French. The official text remains authoritative.

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