It has been reported that France has made an approach to Luxembourg regarding the renegotiation of the existing double tax treaty which is in place between the two countries. At this stage, we have little information on the commencement of such a process, and there has been no information forthcoming from the Luxembourg or French tax authorities on the scope of any changes or, indeed, the timetable for any renegotiation process. The key point of discussion is thought to concern the taxation of capital gains arising on the direct and indirect disposal of French real estate.