Franco – Luxembourg tax treaty will be modified in 2016 for capital gains on properties located in France.
On January 1st 2016, capital gains on transfer of properties located in France and owned by Luxembourg companies like a SOPARFI via a french company like an SCI (Société Civile Immobilière), will be taxed in France, and not anymore in Luxembourg.
See the PDF DOCUMENT : AVENANT DU 5 SEPTEMBRE 2014
This will have a deep impact on real estate strategies of Luxembourg companies, as capital gains in Luxembourg were often excluded from any tax, and it will be taxed in France at the rate 33,1/3 % as from next January 1st 2016.