2. A Paraguayan company also has a store in Paris, without having created a subsidiary. It has recorded dividends received from a 4%-owned subsidiary in Australia (a company incorporated under Australian law) as a liability on its balance sheet, and the shares of this subsidiary have been recorded on the balance sheet of the Paris-based store. What is the method to eliminate the double taxation provided by the treaty between France and Australia for dividends paid by an Australian company to a French resident? Can the Paris-based store invoke the treaty between France and Australia to benefit from these provisions ?