No tax treaty between France and Paraguay: French tax and Paraguayan tax

France does not have a tax treaty with Paraguay: the country is not included in the official BOFiP list, which lists the agreements in force as of January 1, 2026. For a French tax resident, this has two effects, as described by the tax authorities themselves. Income from Paraguayan sources remains taxable in France, and the tax paid in Paraguay does not entitle the taxpayer to a tax credit. On the Paraguayan side, a dividend paid to a non-resident is subject to a tax of 15%. This page details these rules. It does not address Paraguayan tax residency, visas, or local social security.

What the official list of conventions says

The French tax authorities (BOFiP) have published Annex BOI-ANNX-000306, "List of tax treaties concluded by France," which came into force on April 29, 2026. The annex specifies that it only includes agreements in force on January 1, 2026. In Latin America, it lists Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Mexico, Panama, and Venezuela. Paraguay is not included.

One limitation: the list says nothing about a text signed but not yet in force on that date.

Paraguayan income of a French resident: taxable in France, without tax credit

A French tax resident is domiciled in France within the meaning of Article 4 B of the French General Tax Code (CGI). The French Tax Administration's Official Bulletin (BOFiP) uses three criteria: the home or principal residence, the professional activity (whether salaried or not), and the center of economic interests. Only one of these criteria needs to be met. A presence of more than six months in the year is not an absolute requirement.

For income from foreign sources, the practical guide to income tax states: "In the absence of a tax treaty, the income is taxable in France." The instructions for form 2047 (income tax return for 2025) specify, in the section on securities and movable capital, that income originating in a country without a tax treaty with France does not qualify for a tax credit. It must be declared as taxable in France, net of any tax withheld abroad. If no tax has been paid locally, the gross amount is entered on form 2047.

In concrete terms, for a Paraguayan dividend: a withholding tax in Paraguay, then French tax on the net amount, without deduction of the withholding tax.

What Paraguay collects

The Paraguayan tax administration is the Dirección Nacional de Ingresos Tributarios (DNIT). The basic legislation is Law 6380/2019. It applies the principle of source tax: personal income tax is levied on income from Paraguayan sources (Article 48). It distinguishes between residents, who are subject to personal income tax (Article 49), and non-residents, who do not meet the residency requirement and do not have a permanent residence in the country (Article 72).

Article 57 classifies as capital income dividends not subject to the Single Tax on Income (IDU), interest paid by residents on deposits, loans and other investments, and capital gains on the sale of real estate, movable property and rights. For the Non-Resident Income Tax (INR), the National Income Tax Directive (DNIT) indicates a rate of 15 %, a withholding form no. 525 and an obligation code of 725. The specific withholding rules for the INR are detailed later in the law; these could not be read.

Paraguayan dividend paid to a French resident: numerical example (fictitious profile)

Situation. Claire, a fictitious profile, is a tax resident of France. She holds shares in a Paraguayan company which pays her a gross dividend of 100,000 (a fictitious monetary unit, for simplicity).

Issue. She wants to know what Paraguay is withholding, and what amount she declares in France.

Strategy. She notes that France does not have a tax treaty with Paraguay. She applies the tax rate for a non-resident beneficiary, namely 15 %. She then declares the dividend on form 2047 for its net amount.

Result. The Paraguayan withholding tax is 15,000, and the amount to be declared in France is 85,000. No tax credit is deducted from the French tax. For comparison, a resident beneficiary would have incurred 8,000 in withholding tax: the difference is 7,000, or 7 percentage points. The French tax on the 85,000 depends on the tax brackets and Claire's situation: it is not calculated here.

Exchange of information and declaration of accounts

The absence of a tax treaty does not mean the absence of administrative cooperation. The annex to the 2027 draft budget law concerning France's information exchange network contains a table of states that have concluded an administrative assistance agreement with France in force as of September 1, 2026. The entry for "Paraguay" appears there, marked with a cross. The excerpt provided does not indicate in which column this cross is located; therefore, the page does not specify the nature of the agreement.

The same document indicates that 11 states and territories are on the French list of non-cooperative states and territories, according to the decree of April 15, 2026: Anguilla, Antigua and Barbuda, Guam, the U.S. Virgin Islands, the Turks and Caicos Islands, Palau, Panama, Russia, American Samoa, Vanuatu, and Vietnam. Paraguay is not included.

Regarding tax reporting, any account opened, used, or closed abroad must be declared annually using form 3916 or 3916-bis, attached to the income tax return. The penalty is €1,500 per undeclared account, according to the tax authorities' website. The website specifies a penalty of €10,000 for an account located in a country that has not signed a tax treaty with the relevant state: Paraguay's inclusion in this category is not established here and is verified on the date of the tax return.

French income of a resident of Paraguay

The reverse follows the same logic. A non-resident is taxed only on their French-source income, subject to tax treaties. The minimum rate is 20% of taxable income up to €29,579 and 30% of taxable income above that amount, for income received in 2025. Dividends from French sources paid to a non-resident are subject to a withholding tax of 12.80% of taxable income (rate in effect as of January 1, 2026), subject to more favorable provisions in tax treaties. As no treaty is listed for Paraguay, no treaty reduction is mentioned here.

Dual residence: what this page does not address

Tax treaties categorize dual residents according to a specific order: permanent home, closest personal and economic ties, habitual residence, and nationality. The BOFiP (Official Bulletin of Public Finances), which outlines this order, does not address cases where no treaty exists. Therefore, the relevant page does not explain how to determine dual residency in France and Paraguay: the Paraguayan residency criterion for an individual could not be found in the official source.

What changes depending on your situation

• Your tax residence: France, Paraguay, or a situation in between.
• The nature of the income: dividend, interest, capital gain, rent.
• The status of the beneficiary: natural person or company.
• The amount withheld at source and the date of payment.
• Accounts or contracts held in Paraguay must be declared in France.

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

What this page does not cover

It does not specify the criteria for tax residency in Paraguay, nor does it cover wealth tax, inheritance tax, social security contributions, visas, or residence permits. Local tax matters should be clarified with a Paraguayan tax professional; French tax matters are addressed in our sections on tax domicile, the 2047 tax return, and form 3916.