The France-Armenia tax treaty: two royalty rates, an amendment on the elimination of double taxation

The France-Armenia convention establishes two ceilings for royalties: 5 % for copyright and 10 % for other royalties. Dividends are capped at 5 % or 15 %, and interest at 10 %. It was signed in Paris on December 9, 1997, and an exchange of letters in 2003 and 2004 amended Article 23.

A 1997 agreement, an amendment, the MLI in 2024

The convention entered into force on May 1, 2001, and has been applicable since January 1, 2002 (Article 30). The amendment, in the form of an exchange of letters signed in Yerevan on February 5, 2003, and February 3, 2004, modifies Article 23 and entered into force on December 7, 2006. The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies the convention among those concerning income and wealth; no provisions on inheritance or gifts are mentioned. The MLI (Multilateral Income Tax Agreement) takes effect in France on January 1, 2024, for taxes withheld at source and on July 1, 2024, for other taxes. A benefit is denied if obtaining it was one of the main objectives of a tax arrangement.

Armenia: Maximum Detentions and Key Rules

For interest, paragraph 3 of Article 11 reserves taxation to the State of the beneficial owner in four cases: State and local authorities, claims referred to by the formula "guaranteed or insured by a Contracting State", credit sales between companies, loans granted by a bank.

Royalties of €40,000: numerical example (fictitious profile)

Situation. A company resident in Armenia, fictitious profile, receives €40,000 in gross royalties from a French company.

Issue. The ceiling depends on the nature of the fee.

Strategy. It first qualifies the income: use of a copyright, or other royalty, before applying Article 12 § 2.

Result. At 5 %, the ceiling is €2,000. At 10 %, it is €4,000, i.e., €2,000 more. These are maximums stipulated by the agreement, not the tax due.

The fiscal year according to the 183-day rule

Article 15, paragraph 2(a), stipulates a stay not exceeding 183 days during any twelve-month period beginning or ending in the relevant tax year. Two other conditions in the text, concerning the employer and the permanent establishment, must also be examined. For self-employed individuals, Article 14 does not specify a minimum duration, but rather a fixed, customary basis.

Residence, pensions, fortune

Article 4, paragraph 2, distinguishes between a person resident in both States: permanent home, then, if they have homes in both States, center of vital interests; habitual residence; nationality; and agreement of the authorities. Article 18 reserves pensions linked to previous employment to the State of residence. Article 22 (wealth, not gains as defined in Article 13) links real estate to the State where it is located and addresses a substantial shareholding, of at least 25% of the profits, held at any time during the five years preceding the transfer. The text refers to the wealth tax: the French real estate wealth tax (IFI) is not addressed here.

Article 23: The French tax credit

France grants a tax credit against French tax. For income not listed in paragraph ii), it is equal to the corresponding French tax. For income subject to French corporate income tax and falling under Articles 7, 10, 11 § 2, 12 § 2, 13 §§ 1 and 2, 15 § 4, 16 and 17 §§ 1 and 2, it is equal to the Armenian tax paid, without exceeding the corresponding French tax. Version prior to the amendment not reproduced.

What this sheet does not cover

The Armenian tax itself, the IFI, gifts, inheritances and the definition of permanent establishments are not covered.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the royalty: copyright or other.
• The share of capital held and its duration.

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