Where a company having its registered office in France and liable to the tax provided for in Chapter II of this Title carries on business in Saint-Pierre-et-Miquelon, Mayotte, New Caledonia, French Polynesia, the Wallis and Futuna Islands and the French Southern and Antarctic Territories where taxation is applied to distributions of profits, the double taxation to which distributions of profits made by this company may be subject as a result is avoided, in terms of reciprocity, by means of agreements to be concluded between the tax authorities of mainland France and those of the communities concerned.
These agreements apportion the taxation of profits according to a quota determined on the basis of the activity that the company carries out in France and in each of these collectivities.
They are the subject of decrees, countersigned by the competent ministers, which are submitted within three months for legislative ratification.