The France-Singapore tax treaty, point by point

The tax treaty between France and Singapore was signed in Singapore on January 15, 2015. It has been in force since June 1, 2016, and replaces the treaty of September 9, 1974. It applies only to income taxes: neither wealth nor inheritance taxes. For dividends, withholding tax is capped at 15% of the gross amount in general; for interest, the tax levied by the source state cannot exceed 10%. It is also included in the list of treaties amended by the Multilateral Tax Convention (MLI).

A text from 2015 that replaces the one from 1974

The convention was signed in Singapore on January 15, 2015. The French and English texts are equally authentic.

It was approved by Law No. 2016-233 of March 1, 2016 and published by Decree No. 2016-896 of June 30, 2016, in the Official Journal of July 2, 2016. It entered into force on June 1, 2016.

The application dates differ depending on the state and the tax.

It replaces the agreement of September 9, 1974, which had been amended by an addendum of November 13, 2009. The administration's commentary bears the reference BOI-INT-CVB-SGP. This version of the commentary dates from August 7, 2017, and does not mention the MLI: it should be read in conjunction with the list of agreements amended by the MLI, presented below.

The Multilateral Convention (MLI)

Singapore is included in the administrative list of conventions amended by the multilateral convention (BOI-ANNX-000511, dated April 29, 2026). The effective date in France is set for January 1, 2020 for taxes withheld at source and October 1, 2019 for other taxes.

The consolidated text published by the administration mentions the multilateral convention, signed in Paris on June 7, 2017, and an anti-abuse clause based on "one of the principal purposes of an arrangement." This page does not detail the other amendments that the MLI makes to the convention: these are examined on a case-by-case basis.

The taxes in question

The administrative list classifies this convention under the heading "IR": it concerns income tax. From the Singaporean perspective, this refers to income tax. From the French perspective, it includes income tax, corporate tax, social contributions (CSG and CRDS), and withholding taxes.

The convention does not cover wealth tax or inheritance tax. Furthermore, the administrative list contains no line item for inheritance tax in Singapore.

Income-based rules

Dividends and interest

For dividends (Article 10, § 2), the text caps the withholding tax at 5% of the gross amount when the beneficial owner is a company that directly or indirectly holds at least 10% of the capital, and at 15% in all other cases. The exact conditions are detailed in the article before any decision is made.

For interest, the state of residence may tax it. The other state may levy a tax not exceeding 10% of the gross amount. For certain types of interest, the text reserves taxation to the state of residence.

A cap is not a mandatory rate. It sets a maximum that the source state can levy. The actual rate applied depends on that state's domestic law, which this page does not cover.

Royalties

Royalties are taxable only in the State of residence of the beneficial owner. Artistic or literary copyrights and business experience, however, are taxable in the State from which they originate (§ 3).

Capital gains

For capital gains on real estate, the convention stipulates the state where the property is located. Other assets are governed by other sections of the same article. These are not detailed here and should be consulted before any transaction.

Wages and the 183-day rule

The general rule is that the state of residence is the determining factor: the wages of a resident of one state are taxable only in that state, unless the employment is carried out in the other state.

The exception (Article 14, § 2) applies when the stay in the other State does not exceed a total of 183 days in any twelve-month period beginning or ending during the tax year in question. It also requires that the employer is not a resident of the State where the work is performed and that the remuneration is not borne by a permanent establishment located in that State. Read the article before making any calculations.

If both France and Singapore consider you a resident

The convention makes the distinction. Its concept of resident takes precedence over domestic tax domicile. Article 4, § 2 of the convention differentiates between the two, in this order: permanent home, center of vital interests, habitual residence, and finally, agreement between the competent authorities. Nationality is not included, contrary to the general framework described by administrative doctrine.

Inheritance and wealth

The convention does not address them. The administrative list does not mention any succession convention for Singapore. Before making any transfer decision, verify the status of each asset according to the domestic law of each country.

What this page does not cover

Pensions, the elimination of double taxation (tax credit or exemption), capital gains excluding real estate, and each state's internal rules are addressed in the text. Singaporean taxation itself is not covered here.

Numerical example (fictitious profile)

Situation. A French employee, a fictitious profile, residing in Singapore, is employed by a Singaporean company. He undertakes three missions in France over the same twelve-month period: 52, 47 and 38 days.

Issue. He wonders which state can tax the remuneration for days worked in France. The basic rule refers to the state of residence, unless the job is performed in the other state. The exception is based on the length of stay.

Strategy. He keeps a daily tally, before having the other conditions and the reference period of the text examined.

Result. His three assignments total 137 days: the 183-day duration requirement is met, with a 46-day margin. A fourth assignment of 50 days would bring the total to 187 days: the duration requirement would no longer be met, with a 4-day overrun. The calculation covers any twelve-month period beginning or ending during the fiscal year in question, not just the calendar year; the other conditions remain to be verified in the text.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income: dividend, interest, royalty, capital gain, salary.
• The location where the job is performed and the number of days spent in each state.
• The nature of your assets: real estate, securities or other.
• The effects of MLI on your situation.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.