The 1996 France-Russia tax treaty, partially suspended since 2023

The convention of November 26, 1996, still exists, but it has been partially suspended since August 8, 2023. Articles 5 to 22 and 24, and points 2 to 9 of the protocol, no longer apply: reduced withholding tax rates can no longer be granted, each state applies its own domestic law, and Russian taxes do not give rise to any tax credit in France. This page describes the official status as found in the BOFiP (Official Bulletin of Public Finances) and the administrative list of April 29, 2026. It does not address Russian law.

A text from 1996, partially suspended on August 8, 2023

The convention was signed in Paris on November 26, 1996, with a protocol forming an integral part thereof. It entered into force on February 9, 1999. It is amended by the multilateral convention (MLI), which took effect on January 1, 2021 for withholding taxes and on November 30, 2020 for France for other taxes.

The administrative list of conventions (BOI-ANNX-000306, version of April 29, 2026) includes the line "C November 26, 1996 (Official Journal of May 29, 1999)", income and wealth tax, with the note: "Partial suspension of the convention as of August 8, 2023". It does not mention inheritance or gifts.

Who suspended what?

According to the BOFiP (BOI-INT-CVB-RUS, version of October 23, 2024), Russia suspended, by Presidential Decree No. 585 of August 8, 2023, ratified by Law No. 598-FZ of December 19, 2023, the application of Articles 5 to 22 and 24 and points 2 to 9 of the Protocol, effective August 8, 2023. France suspended the same provisions under the principle of reciprocity, pursuant to Article 55 of the 1958 Constitution. The notice announcing the suspension could not be read.

The suspended items include, in particular, permanent establishments (5), real estate income (6), profits (7), dividends (10), interest (11), royalties (12), gains (13), salaries (15), pensions (18), other income (21), and capital (22). Items 1 to 4, 23, and 25 to 29 are not included in this list. For items 1 to 4 and 25 to 29, the BOFiP (Official Bulletin of Public Finances) does not explicitly state their remaining status.

Income by income: what the suspension changes

The grace periods are: August 7 and September 30, 2023

The BOFiP (Official Bulletin of Public Finances) maintains the agreement for prior situations. Dividends for which the distribution decision was made no later than August 7, 2023, remain eligible under Article 10. Interest and royalties relating to periods ending no later than August 7, 2023, are also eligible, pro rata temporis where applicable. Gains from disposals completed no later than August 7, 2023, remain covered by Article 13. For business profits and self-employment, the tolerance applies to fiscal years beginning no later than August 7, 2023, and not exceeding 12 months. For salaries, pensions, and public remuneration, it applies, by way of tolerance, to periods ending no later than September 30, 2023.

Dividends decided before or after August 7, 2023: numerical example (fictitious profile)

Situation. A company decides to distribute dividends on June 21, 2023, and a second one on September 12, 2023. The beneficiary is a resident of France, a fictitious profile.

Issue. He wonders if Article 10 still applies to each one.

Strategy. It compares the date of each distribution decision to the deadline of August 7, 2023.

Result. The first decision is dated 47 days before the deadline: it is eligible for the benefits of Article 10. The second is dated 36 days after: it is not, and domestic law applies. The difference in dates is the only determining factor, regardless of the amount paid. The dates and profile are fictitious.

Real estate assets: 2023 under agreement, 2024 without

The event triggering the French wealth tax (IFI) is the ownership of taxable real estate assets on January 1st. According to the French tax authorities (BOFiP), assets held on January 1st, 2023, remain taxable for that year under the terms of the tax treaty. The treaty ceases to apply to tax years from January 1st, 2024 onwards. The rules governing the territorial application of the IFI then become governed by domestic law.

Double taxation: Article 23 is rendered inoperative

Article 23 limits its application to taxes levied in accordance with the convention. Taxes based solely on Russian or French domestic law are not subject to this agreement. The French tax authorities (BOFiP) therefore conclude that Article 23 is inoperative: Russian taxes on the income in question do not give rise to any tax credit in France. They are deductible from the French tax base under the standard rules.

Russia is on the French list of non-cooperative tax jurisdictions.

The appendix to the 2027 draft budget law indicates that 11 states and territories are included on the list of non-cooperative states and territories, including Russia, following the decree of April 15, 2026. The French tax authority (BOFiP) specifies that Russia has been on this list since the decree of February 16, 2024, and that, as a result of this inclusion, the deduction from taxable income, as well as corporate income tax, of sums paid to Russian individuals is generally excluded, unless proof is provided that the expenses correspond to genuine transactions that are neither abnormal nor excessive, with a primary purpose other than transferring the burden to a non-cooperative state (Article 238 A of the French General Tax Code). The list is verified on the date of the transaction.

European Union sanctions: what the Treasury says

The Treasury's "Russia Sanctions" page, published on March 19, 2026, indicates that Regulations 833/2014 (sectoral measures) and 269/2014 (asset freezes) apply, including the 19th package adopted on October 23, 2025. According to this page, they apply to individuals who are nationals of a Member State, whether inside or outside the Union, to legal entities constituted under the law of a Member State, and to any economic activity carried out wholly or partly within the Union. These measures are separate from the tax treaty. The Treasury page mentioned the 19th package as the most recent; please verify the status of sanctions and lists as of the date of this transaction.

What this page does not cover

Russian tax law, the effect of the suspension on Articles 1 to 4 and 25 to 29, details of sanctions and asset freeze lists, French reporting obligations for accounts and contracts held in Russia, and inheritance matters. For any ongoing situation, a local professional and specialized sanctions counsel are necessary.

What changes depending on your situation

• The nature of the income and the date of the decision, period or transfer.
• Your tax residence and the location of your assets.
• The payment or non-payment of Russian tax, and the fate of its deduction in France.
• The inclusion of the counterparty on the freeze lists.

A text must be read in light of the facts in your case. No outcome is guaranteed.