The convention between France and Jamaica was signed in Kingston on August 9, 1995, and entered into force on May 21, 1998. It only concerns income taxes. It caps withholding tax at 10 % or 15 % on dividends, at 10 % on interest, and at 10 % on royalties. This page reads the official text and explains what it does not cover.
A 1995 text, limited to income, excluding MLI
The administrative list of conventions (BOI-ANNX-000306, dated April 29, 2026) classifies it as "IR": neither wealth, nor inheritance, nor gift. It was approved by Law No. 98-119 of March 2, 1998, and published by Decree No. 98-892 of October 2, 1998. Article 2 refers, for France, to income tax, corporate tax, and payroll tax; for Jamaica, to income tax and transfer tax.
Jamaica is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, of April 29, 2026).
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 10 § 2 | 10 % of the gross amount if the beneficial owner is a company (excluding partnerships) that directly or indirectly holds at least 10 % of voting rights; 15 % in all other cases |
| Interests | 11 § 2 | The withholding tax cannot exceed 10 % of the gross amount |
| Royalties | 12 § 2 | The withholding tax cannot exceed 10 % of the gross amount |
| Capital gains (other assets) | 13 § 4 | Taxable only in the state where the transferor is resident |
| Salaries, exception | 15 § 2 a) | Stay not exceeding 183 days during the tax year in question |
| Pensions | 18 § 1 | Payments made to a resident for previous employment: taxable in the state of residence |
| Double taxation | 22 | Tax credit deductible from French tax; deduction on the Jamaican side |
Who is a resident?
For a person resident in both States, Article 4, paragraph 2, first considers their permanent home; if they have a home in both States, then their center of vital interests. If this center cannot be determined, or in the absence of a home, it considers their habitual residence, then their nationality; in cases of dual nationality or lack of nationality, the competent authorities decide by mutual agreement. French tax domicile is addressed on our page about leaving France.
Salaries: 183 days in the fiscal year
Article 15, paragraph 2(a), sets the threshold at 183 days "during the tax year in question." The calculation therefore covers the tax year, not twelve consecutive months. This threshold alone is insufficient: the same paragraph sets out other conditions, which can be read in the full text of the article before any calculation.
Eliminating double taxation: tax credit in Paris, deduction in Kingston
For a resident of France (Article 22 § 1 a), Jamaican tax is not deductible from the income in question, but entitles the taxpayer to a tax credit against French tax. This credit is equal to the corresponding French tax if the income is taxable only in Jamaica; otherwise, it is equal to the Jamaican tax paid, without exceeding the corresponding French tax. On the Jamaican side (Article 22 § 2), Jamaica grants a deduction against the resident's income tax equal to the tax paid in France. Income from real estate is governed by Article 6 § 1: it is taxable in the State where the property is located.
What this page does not cover
The interest exemptions in paragraph 3 of Article 11, technical services, information exchange, and application to the IFI (Wealth Tax) are not detailed here. Jamaican law is not addressed; it should be verified with a local professional.
Frequently asked questions
What is the withholding tax rate on dividends between France and Jamaica?
10 % of the gross amount for a company holding directly or indirectly at least 10 % of voting rights, 15 % in other cases (Article 10, paragraph 2).
Does the France-Jamaica convention cover inheritances?
The administrative list of April 29, 2026 classifies it as "IR" alone, and article 2 only names income and transfer taxes.
Is the 183-day threshold calculated over twelve months?
No: Article 15 § 2 a) considers the tax year in question.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, advises executives and families whose assets or business activities connect France and Jamaica. To discuss your situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- Tax treaties: countries linked to France
- Dividends paid to a non-resident: withholding tax of 12.8% %
- Foreign capital income: tax credit and form 2047
- Double taxation: tax credit and effective tax rate
- Leaving France: exit tax, tax residence, procedures
- Inheritance agreements: which countries with France
Official sources
- BOFiP doctrine, France-Jamaica convention (BOI-INT-CVB-JAM): https://bofip.impots.gouv.fr/bofip/316-PGP.html
- Text of the convention of August 9, 1995: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/jamaique/jamaique_convention-avec-la-jamaique_fd_1857.pdf
- List of tax treaties (BOI-ANNX-000306): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
- List of agreements modified by the MLI (BOI-ANNX-000511): https://bofip.impots.gouv.fr/bofip/14854-PGP.html/identifiant=BOI-ANNX-000511-20260429