Australian Tax Treaties
French Convention
CONVENTION BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE FRENCH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF FISCAL EVASION
ARTICLE 2
Taxes Covered
1.
The existing taxes to which this Convention shall apply are:
(a) in the case of Australia:
the income tax, and the resource rent tax in respect of offshore projects relating to exploration for or exploitation of petroleum resources, imposed under the federal law of Australia;
(b) in the case of France:
2.
This Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed by a Contracting State in addition to, or in place of the existing taxes to which this Convention applies. The competent authorities of the Contracting States shall notify each other of significant changes which have been made in their law relating to taxes to which this Convention applies.
3.
Notwithstanding paragraphs 1 and 2, the taxes to which Articles 25 and 26 shall apply are:
(a) in the case of Australia, taxes of every kind and description imposed under the federal taxes laws administered by the Commissioner of Taxation; and
(b) in the case of France, taxes of every kind and description imposed on behalf of France or its political subdivisions or local authorities
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
The existing taxes to which this Convention shall apply are:
(a) in the case of Australia:
the income tax, and the resource rent tax in respect of offshore projects relating to exploration for or exploitation of petroleum resources, imposed under the federal law of Australia;
(b) in the case of France:
(i) the income tax ( l ' imp ô t sur le revenu );
(ii) the corporation tax ( l ' imp ô t sur les soci é t é s );
(iii) the additional taxes on corporations ( les contributions sur l ' imp ô t sur les soci é t é s ); and
(iv) widespread social security contributions ( contributions sociales g é n é ralis é es ) and contributions for the reimbursment of the social debt ( contributions pour le remboursement de la dette sociale ), including any withholding tax with respect to the aforesaid taxes.
2.
This Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed by a Contracting State in addition to, or in place of the existing taxes to which this Convention applies. The competent authorities of the Contracting States shall notify each other of significant changes which have been made in their law relating to taxes to which this Convention applies.
3.
Notwithstanding paragraphs 1 and 2, the taxes to which Articles 25 and 26 shall apply are:
(a) in the case of Australia, taxes of every kind and description imposed under the federal taxes laws administered by the Commissioner of Taxation; and
(b) in the case of France, taxes of every kind and description imposed on behalf of France or its political subdivisions or local authorities
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