When payments, expenses or losses deductible from the taxable income of a taxpayer who is resident in France and in another State pursuant to the rules of that State are taken into account in both States, their deduction is not allowed in France.
However, this deduction is allowed in France when:
1° The payment, expense or loss likely to be the subject of a double deduction is included in the taxable income of the beneficiary or, in the case of a loss, of the taxpayer in France and in the other State;
2° The other State is a Member State of the European Union which refuses the deduction and the tax treaty linking it to France fixes the residence of this taxpayer in France.