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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: France: Relief from French tax

France publishes form on which to claim relief from French tax under the convention. These may be obtained from:

the website of the French embassy in London {#}


Centre des impôts des non-résidents, 10 RUE DU Centre, 93 465 Noisy-le-Grand Cedex, France.

The claimant should complete the form in triplicate and send it to his Tax Office. If the necessary conditions are satisfied (see INTM162030), the certificate will be completed, signed and stamped. One copy will be retained by the tax office, the remaining copies returned in accordance with the directions on the explanatory note which is incorporated in the claim forms.

The forms are

Claims for relief at source on dividends

Portfolio investors may be able to arrange with the French payer of a dividend to receive French dividends under deduction of tax at the agreement rate of 15 per cent instead of suffering French withholding tax at 25 per cent A simplified certificate may be supplied to the French paying agent, in a form prescribed by the French authorities, confirming that the claimant is

(a) UK resident,

(b) the owner of the shares as well as the dividends


(c) has no permanent establishment in France with which the shares are effectively connected.

The claimant will need to obtain a certificate from his tax office confirming that the declarations given are correct.

Institutional investors

Institutional investors, for example, investment trusts, which are residents of the United Kingdom, may by prior claim to the Service de la Législation Fiscale, Sous-Direction E, 139 rue de Bercy, 75572 Paris, Cedex 12 be authorised to claim the reduction in withholding tax direct from the French paying establishment.

Where this procedure has been authorised by the Direction Générale des Impôts the claimant will be required to complete an appropriate form before obtaining refunds from the paying establishment. The relevant form may be obtained from

  • Centre des impôts des non-résidents, 10 rue du Centre, 93 465 Noisy-le-Grand CEDEX, France or
  • the French banks or financial institutions concerned.