Convention du 22 décembre 2005 signée entre la France et la Lybie dans le but d'éviter les doubles impositions
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La France et la Lybie ont signé le 22 décembre 2005 une convention en vue d'éviter les doubles impositions et de prévenir l'évasion fiscale en matière d'impôts sur le revenu. Le projet de loi autorisant l'approbation de cet accord a été déposé le 5 juin 2007 au Sénat qui entrera en vigueur après ratification des deux Etats. Les principales dispositions de cet accord sont notamment la définition d'un établissement stable qui est un chantier de construction ou de montage qui dure plus de trois mois. Il indique ensuite que l'Etat de la source pourra imposer les dividendes à un taux qui ne pourra être supérieur à 10 % de leur montant brut et 5 % pour les sociétés bénéficiaires détenant au moins 10 % du capital de la société distributrice. De plus, il stipule que les intérêts payés à un résident de l'autre Etat contractant seront exclusivement imposables dans l'Etat de résidence du bénéficiaire. Par ailleurs, le taux limite de retenue à la source est fixé à 10 %, toutefois...
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