The France-Jordan tax treaty: what the text says

The convention between France and Jordan was signed in Amman on May 28, 1984 and entered into force on April 1, 1985. It has been modified by the multilateral convention (MLI) since 2021. Its particularities: three royalty rates according to the nature of the right, and, for France, the exemption of income taxable in Jordan, except those of articles 10, 11, 12, 14, 16 and 17, which give entitlement to a tax credit.

A text from 1984, the MLI since 2021

The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it as "IR" (income tax) and makes no mention of inheritance or gifts. According to the BOFiP doctrine (BOI-INT-CVB-JOR), the convention was approved by Law No. 85-12 of January 3, 1985, and published by Decree No. 85-411 of April 3, 1985. According to the list BOI-ANNX-000511 (same date), the MLI (Mixed Tax Agreement) takes effect on January 1, 2021, for taxes withheld at source and on July 1, 2021, for other taxes. A consolidated version is published by the tax authorities. Article 2 § 3 a) applies to French income tax and corporation tax, including withholding taxes, advance payments, and prepayments.

Maximum deductions and key rules

Who is a resident?

Article 4 § 2 applies to a person resident in both States. It takes into account, in order: a) the State of the permanent home; b) if the center of vital interests cannot be determined, or in the absence of a home in both States, the State of habitual residence; c) nationality; d) failing that, the agreement of the competent authorities.

Royalties: three rates depending on the nature of the right

Article 12 § 2 distinguishes between trademarks (25 %), copyrights on literary, artistic or scientific works (5 %) and all other cases (15 %).

Interests: 15 % and three cases reserved for the State of residence

The ceiling of 15 % of Article 11 § 2 gives way to paragraph 3: interest is taxable only in the State of residence of the beneficiary when it relates to the sale on credit of industrial, commercial or scientific equipment (a), to the sale on credit of goods from one enterprise to another (b) or to a loan granted by a banking institution (c).

France: exemption, except for the income tax credit mentioned in paragraph b

Article 23, paragraph 2, provides that income taxable in Jordan is exempt from French tax, except for the income referred to in subparagraph (b). For income covered by Articles 10, 11, 12, 14, 16, and 17, the Jordanian tax paid entitles the taxpayer to a tax credit, capped at the amount of French tax due on that income. The consolidated text contains two paragraphs designated as "(d)": these should be read in full.

What this page does not cover

Point 5 of the protocol (including subparagraph b), the derogation from paragraph 4 of Article 13 (for shares and units), Articles 14, 16, and 17, the exchange of information (Article 26), and the application to the IFI (French Wealth Tax) are not detailed. Jordanian law is not addressed; its validity should be verified with a local professional.