(b) “France” means the European and overseas departments of the French Republic, including the coastal sea and the airspace beyond, as well as the territories where the French Republic has, in accordance with international law, sovereign rights for the exploration and exploitation of the natural resources of the seabed and its subsoil and the upper waters 3. This article shall not be construed as requiring a State Party to grant compensation, exemptions and reductions to residents of the other State Party by virtue of civil status or family obligations it grants to its own residents. 4. A citizen residing in Canada who receives dividends paid by a company established in France shall be entitled to reimbursement of the advance if it is not entitled to obtain payment from the French Ministry of Finance in accordance with paragraph 3(a), to the extent that the advance was actually paid by the company in respect of the dividends. The gross amount of the advance repaid is considered a dividend within the meaning of the agreement. It may be taxed in France in accordance with paragraph 2. 2. Without prejudice to paragraph 1 of this Article and Article 7, profits derived from the operation of ships or aircraft primarily used for the carriage of persons or goods exclusively between places in a Contracting State may be taxed in that State. 2.
Notwithstanding paragraph 23 above, war pensions and allowances (including pensions and allowances paid to combat veterans or paid as a result of damage or injury resulting from war) that occur in one State Party and are paid to a State established in the other State Party shall be exempt in that other State, notwithstanding paragraph 23 of this Article, if they come from a resident of the first-mentioned State. 5. The term “dividends” as used in this Article means income from shares, “enjoyment” shares or “enjoyment” rights, mining shares, founder shares or other rights other than claims on debts, participation in profits and income subject to the tax treatment of distributions or the same tax treatment as income from shares under the law of the Contracting State in which the distributing company is established. 7. Notwithstanding the provisions of this Article, for the purposes of the imposition of the solidarity tax on the net assets referred to in Article 2(3)(b) of a natural person established in France and having the nationality of Canada but not French nationality, the assets held outside France held by that person on the first of January of each of the five years shall be: after the calendar year in which he resides in France, he is excluded from the tax base for each of those five years. If such a person loses the status of resident in France for a period of at least three years and then re-sequenced in France, the assets held outside France are those held by such a person on the first january of each of the five years following the calendar year in which he or she returned to france: of the tax base for each of those five years. 3. Articles 16, 17 and 20 shall apply to remuneration and pensions for services provided in the course of an activity carried on by a Contracting State, a political subdivision or a local authority. 4. Capital represented by shares or other rights (with the exception of shares or other rights referred to in paragraph 2) which form part of a substantial interest in a company established in a Contracting State may be taxed in that State. There is an essential interest when a natural person, alone or with related persons, holds, directly or indirectly, shares or other rights the sum of which entitles him to at least 25% of the profits of the company.
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