The 1973 France-Iran tax treaty: withholding taxes and exemptions in France

The France-Iran convention, signed in Tehran on November 7, 1973, is on the list of conventions in force as of January 1, 2026. It concerns income tax. It caps withholding tax at 15 or 20 for dividends, 15 for interest, and 10 for royalties. This page reproduces the text as read, without commentary on current events.

A text from 1973, in force since April 10, 1975

The convention was approved by Law No. 74-1010 of December 2, 1974, and published by Decree No. 75-302 of April 17, 1975. It entered into force on April 10, 1975. Article 29 stipulates that withholding taxes apply to sums paid from that date. For other taxes, it uses the year 1976 in France and the fiscal year beginning March 21, 1976, in Iran.

List BOI-ANNX-000306 (April 29, 2026) classifies it with the sole designation "IR", without a note. Iran is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, April 29, 2026).

Maximum deductions and key rules

Dividends: 15 % or 20 % depending on the direct holding of 25 %

The 15 % limit applies if the beneficiary is a company, excluding partnerships, that directly holds at least 25 % of the capital of the paying company. In all other cases, the limit is 20 %.

The 183-day threshold: the fiscal year

For wages, Article 15 § 2 a) refers to a stay not exceeding a total of 183 days "during the relevant tax year." The reference is the tax year, not a period of twelve consecutive months. The text adds two conditions, concerning the employer and the payment of remuneration by a permanent establishment or fixed base.

Public pensions and salaries

Article 18 reserves pensions paid for previous employment to the State of residence, subject to Article 19, paragraph 1. The latter makes taxable in the State paying them remuneration and pensions paid by a State, a local authority, or a public institution for functions of a public nature. Article 19, paragraph 2, refers to Articles 15, 16, and 18 for services rendered in a commercial or industrial activity.

In France: exemption of other taxable income in Iran

Article 23, paragraph 2(a), exempts from French tax income other than that referred to in subparagraph (b) when it is taxable in Iran under the convention. Subparagraph (b) deals in particular with dividends, interest, and royalties, with a tax credit.

Residence

Article 4, paragraph 1, defines a resident as any person liable to tax in a State under its legislation. Paragraph 2 distinguishes between dual residence: permanent home, center of vital interests, habitual residence, nationality, and a decision by the competent authorities by mutual agreement.

What this page does not cover

It does not address Iranian domestic law, the exclusion of certain income provided for in Article 1, the exchange of information, the mutual agreement procedure, the IFI, or the practical application of the convention.

What changes depending on your situation

• The nature of the income and its state of source.
• The level of direct ownership of the company that pays the dividends.
• Your residence as defined in Article 4.
• The fiscal year in which your stays fall.

The text should be read in conjunction with the documents in your file; no result is guaranteed in advance.