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Published online by Cambridge University Press: 05 November 2014
The relevance of the OECD and UN Model Conventions and their Commentariesfor the interpretation of French tax treaties
The current French tax treaty network is the heritage of quite an old practiceand probably one of the most impressive in the world: more than 120 treatiesrelating to taxes on income (including wealth taxes) and taxes on capital.
Some treaties are particularly important in this network either because they areparticularly innovative (for example, the new treaty with the USA) or becausethey are particularly exceptional (for example, the treaty with Monaco).Furthermore, regarding the exercise of its taxation rights, France is in arather odd situation. As regards the application of the Tax Code, it isnecessary to differentiate between France (including the French overseasdepartments, Départements d'Outre-Mer (DOM), i.e.Guyana, Martinique, Réunion and Guadeloupe) and other overseasterritories which – geographically speaking – are still parts ofFrance but which are fiscally autonomous. These are New Caledonia, FrenchPolynesia, Wallis and Futuna, Saint Pierre and Miquelon, Mayotte,Saint-Barthélemy, the French part of Saint Martin and the French Southernand Antarctic Lands. Some of them have treaties with France (French Polynesia(1957), New Caledonia (1983), Saint Pierre and Miquelon (1988) and Mayotte(1970)).
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