France China double tax convention. Is an individual a tax resident because of his liability to tax or is he liable to tax in consideration of his state residency?
The French administrative suprême court (Conseil d’État) ruled, with regard to the tax treaty between France and China of 30 May 1984, that the mere fact of being subject to tax in China is not sufficient to be considered as a Chinese resident and therefore to benefit from the provisions of this treaty[1].
Background
A manager of a newly ope...