The France-Saudi Arabia tax treaty: a 1982 agreement renewed every five years

The tax treaty between France and Saudi Arabia was signed in Paris on February 18, 1982. It does not stipulate any withholding tax rate on dividends: Article 6 reserves this tax for the recipient's country. It is not indefinite: it is renewed for five-year periods, with the latest renewal beginning on January 1, 2024. This page presents what we have been able to find in the consolidated text and explains what it does not cover.

A text from 1982, two amendments and a renewal every five years

The original text. The convention was signed in Paris on February 18, 1982, with a protocol forming an integral part thereof. It entered into force on March 1, 1983 (Law No. 82-1092 of December 23, 1982, Decree No. 83-586 of June 28, 1983). The administrative list of conventions (BOI-ANNX-000306, dated April 29, 2026) classifies it as relating to income tax, wealth tax, and inheritance tax.

The amendments. Two amendments supplement it: one dated October 2, 1991, which entered into force on July 1, 1995, and the other dated February 18, 2011, which entered into force on June 1, 2012. The latter adds Article 18B on the exchange of information. The page does not give its application date: the two sources consulted do not agree on this point, and we are not making a definitive judgment.

The renewal. The convention is renewed for five-year periods by exchange of diplomatic notes (Article 20 § 3). The latest renewal, effective January 1, 2024, resulted from notes verbales signed on December 14 and 28, 2023; the extension was formalized by Decree No. 2024-227 of March 14, 2024. This is a specific point of this text: before developing a long-term strategy, the status of the renewal is verified.

The MLI. The Multilateral Convention (MLI) applies there: for withholding taxes on sums paid from 1 January 2021, and for other taxes on periods beginning from 1 November 2020. The MLI entered into force on 1 January 2019 for France and on 1 May 2020 for Saudi Arabia.

Articles read, in a table

Dividends and debt income: a state rule for the beneficiary, without a rate

Article 6, paragraph 1, stipulates that dividends paid by a company resident in one State to a resident of another "shall be taxable only in that other State." The text does not specify a withholding tax rate. An exception exists: dividends are also taxable in the State of the company if the shareholding is effectively connected with an activity carried on by the recipient there; in this case, Article 14 applies.

Article 7, entitled "Income from Debts" and not "Interest," follows the same logic: income from debts originating in one State and paid to a resident of the other is taxable only in that other State. This concept covers debts of all kinds, including government bonds, their premiums, and their prizes.

Royalties (Article 8 § 1) "are taxable in that other State": the text read does not say "only". We therefore do not present this regime as an exclusive taxation.

The religious tax, Zakat, is among the Saudi taxes covered by Article 2.

Who is a resident?

Article 4, paragraph 1, determines who is liable for tax in a State based on their domicile, residence, place of management, or a similar criterion. For an individual resident in both States, paragraph 2 applies the following criteria in order: a) permanent home, then center of vital interests; b) habitual abode; c) nationality; d) agreement between the competent authorities. For other individuals, the relevant criterion is the place of effective management. French tax domicile is addressed on our page concerning Article 4B.

Employees: the criteria of Article 10 A

In principle, earnings from salaried employment are taxable in the state of residence. Article 10 A § 1 sets out two criteria that link taxation to the other state: a stay in that state "for a period or periods exceeding in total one hundred and eighty-three days" during the tax year in question, or earnings paid by, or on behalf of, an employer who is a resident of that state. The text links these criteria with "or": the two criteria are alternative, and the relevant tax period is the tax year in question.

Earnings, wealth and inheritances

Capital gains. Capital gains on real estate are taxable in the State where the property is located (Article 9, paragraph 1). For other assets, the general rule is taxation in the State of residence of the transferor, unless the asset is connected to a business activity or a fixed base in the other State (paragraph 2). Capital gains on a substantial interest are taxable in the State of the company, subject to a threshold of 25% of profits (paragraph 3).

Fortune. Article 14 A deals with wealth. Paragraph 4 stipulates taxation solely in the state of residence for anything not covered above. The list of taxes covered includes the French wealth tax (Impôt de Solidarité sur la Fortune). The tax authorities' commentary examines Article 14 A with regard to the real estate wealth tax (Impôt sur la Fortune Immobilière). We will not elaborate on it here.

Inheritance. Real estate is subject to inheritance tax only in the state where it is located (Article 17 § 1). Business assets are taxable in the state where the business is conducted; other movable assets are taxable in the state of residence of the deceased at the time of death. The administrative list indicates the presence of inheritance provisions for Saudi Arabia.

Avoiding double taxation: Article 15

Saudi Arabia avoids double taxation under its domestic law. France exempts certain Saudi-source income: real estate income, gains under Article 9 § 1, and business profits under Article 14. It grants a tax credit for Saudi tax on other eligible income. This mechanism is generally explained on our page about tax credits and effective tax rates.

Exchange of information and entitlement to benefits

Since the 2011 amendment, Article 18 B governs the exchange of information "likely to be relevant" for the application of the convention or domestic laws. Information cannot be refused solely on the grounds that it is held by a bank, financial institution, agent, or trustee.

The preliminary clause on the right to benefits begins with "Notwithstanding the other provisions of this Convention." It applies pursuant to Article 7 of the MLI.

What this page does not cover

Private sector retirement pensions, the implementation of the 2011 amendment over time, the most-favored-nation clause of Article 18A, and Saudi tax law itself are not addressed. No official Saudi sources could be consulted for this page.

The 183-day threshold: a numerical example (fictitious profile)

Situation. A French resident executive, a fictitious profile, makes three business trips to Saudi Arabia: 120, 45 and 30 days.

Issue. He wants to know if the residency requirement of Article 10 A is met.

Strategy. He keeps a daily tally and adds up the stays, then has the alternative criterion of the employer being resident in the other state examined.

Result. The total is 195 days: the benchmark of 183 days is exceeded by 12 days. Without the third stay, the total would be 165 days; with 10 days instead of 30 for this third stay, it would be 175 days, a margin of 8 days. This calculation assumes that the three stays fall within the same tax year, the accounting period used in the legislation. It is not a definitive conclusion: the legislation links the 183-day criterion and the resident employer criterion with an "or" clause, and only one of the two is required (for employment in Saudi Arabia).

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income: dividend, debt, royalty, salary, gain.
• The number of days spent in each state and the counting period.
• The nature of your assets, for wealth and inheritance.
• The status of the renewal of the agreement as of the date of your decision.

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