HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: France: Treaty Summary

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

Treaty summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and France are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details.

Portfolio dividends 15% (note 1) Article 11
Dividends on direct investments 0% (note 2) Article 11
Conditions for lower rate on dividends on direct investments The beneficial owner must be a company liable to corporation tax which holds, directly or indirectly, at least 10% of the capital of the payer Article 11
Property income dividends 15% (note 2) Article 11
Interest 0% Article 12
Royalties 0% Article 13
Government pensions Taxable only in France unless the individual is a resident of, and a national of, the UK and not also a national of France (note 3) Article 18
Other pensions/annuities Taxable only in the UK (note 3) Article 17 and Article 23
Arbitration Yes Article 26


Note 1: This rate is also available to pension funds that are not companies, notwithstanding that France does not consider such funds to be persons who are resident in the United Kingdom.

Note 2: REIT dividends are taxed at the rate provided for by the domestic law of the Contracting State in which the dividends arise where the beneficial owner holds 10% or more of the capital of the distributing vehicle (see Article 11(5)).     

Note 3: Some French pensions, those payable because of persecution and those payable for reasons of illness or injury following the termination of service in the armed forces, are exempt from tax in both countries (Article 19(4)).