Tax treaties: countries linked to France, and how to read the official list

The official list of tax treaties concluded by France is published in the BOFiP (Official Bulletin of Public Finances), in Appendix BOI-ANNX-000306. The current version is dated April 29, 2026. It only lists treaties in force on January 1, 2026. For each country, a column indicates the taxes covered: income tax (IR), wealth tax (IF), inheritance tax (S), gift tax (D), and registration duties (DE). A country may appear in the list even if the treaty does not cover all of these taxes.

This page explains how to read the list. It does not reproduce it in its entirety, does not give the total number of agreements, and does not detail the content of any agreement (rates, residence, withholdings).

What the list contains

The annex is a table with three columns: the State or territory; the dates of the convention, amendments, special agreements or exchanges of letters, with their publication in the Official Journal; the taxes concerned and their specificities.

When the administration publishes this table, it specifies that it only indicates agreements in force on January 1, 2026. For those that are not in force or that come into force after this date, it refers to the Treaties and Agreements database of the Ministry for Europe and Foreign Affairs.

A few lines to learn how to read

The lines below are examples of reading. They come from the "Taxes Covered" column of the appendix. They do not reveal the content of the conventions.

Three useful readings:

• Multiple texts for the same country. Luxembourg has one convention and two amendments; Portugal displays IR and S-D in separate cells. Read the entire line.
• Read the letters, nothing more. The Singapore line only mentions IR. The Emirates line mentions IR, IF and S. The list doesn't say anything more: the content is found in the convention.
• Monaco is presented separately. The tax column indicates a tax treaty "not primarily intended to avoid double taxation," followed by inheritance tax. Do not read it in the same way as the other lines.

Suspended or terminated agreements

Footnotes indicate special cases as of the date of the list.

The appendix contains a footnote for each of these five states. Before relying on a convention, read the footnote.

What is the purpose of a convention?

According to economie.gouv.fr, tax treaties serve to avoid double taxation and determine which country has priority for taxing income. In the absence of a treaty, the domestic law of each country applies. Regarding residency, the concept of resident as defined by the treaty takes precedence over that of tax domicile under domestic law (BOI-INT-DG-20-10-10, paragraph 40). Our page on principal activity and tax domicile describes the domestic rule.

Where to read the text of a convention

For Luxembourg, the BOFiP (French Official Tax Bulletin) publishes a dedicated document, BOI-INT-CVB-LUX (published on February 23, 2021), which includes three sub-documents: scope of application, taxation of certain categories of income, and procedures for avoiding double taxation and other miscellaneous provisions. The consolidated text of the France-Luxembourg tax treaty, signed on March 20, 2018, and supplemented by two amendments, is published on impots.gouv.fr. This page does not include the texts for other countries.

The list of conventions itself comes from the BOFiP annex.

French tax treaties: a numerical example (fictitious profile)

Situation. Elise, a business owner, compares six destinations: Singapore, Cyprus, the United Arab Emirates, Portugal, Hong Kong, and Luxembourg. She wonders which ones have a tax treaty in place for each tax.

Issue. How many of these six lines mention inheritances?

Strategy. Read the "Taxes concerned" column of the BOI-ANNX-000306 appendix for each of these six States, then count.

Result.

Inheritance is only mentioned on two out of six lines. The list doesn't mention the other four: this doesn't reveal the content of the agreement. Elise needs to consult the documents before making a decision.

This profile is fictitious. The figures count mentions in a list; they do not measure protection or tax advantage (count on the six lines of the list).

French tax treaties: what changes depending on your situation

• Your destination country and the presence of multiple lines in the list.
• The tax that interests you : income, wealth, inheritances, gifts.
• The date of the convention and its amendments.
• A suspension or a denunciation indicated by a note.
• Your residency situation, which determines which convention applies.

The rule depends on your situation. No results are guaranteed.