The France-Kyrgyzstan tax treaty: a text signed with the USSR in 1985

For Kyrgyzstan, the administrative list cites the convention concluded with the former USSR on October 4, 1985, which legal doctrine indicates continues to have effect with respect to Kyrgyzstan. It caps the withholding tax at 15 % on dividends and at 10 % on most interest. This page reads this text and explains what it does not address.

A convention signed with the USSR, applied to Kyrgyzstan

The administrative list (BOI-ANNX-000306, dated April 29, 2026) cites, for Kyrgyzstan, the convention of October 4, 1985 (Official Journal of May 28, 1987) and an exchange of letters dated March 14, 1967. It classifies it as "IR": neither wealth, nor inheritance, nor gift tax. The BOFiP page (BOI-INT-CVB-KGZ, in force since September 12, 2012) indicates that the convention entered into force on March 28, 1987, and "continues to have effect with respect to Kyrgyzstan." On the French side, it concerns income tax and corporation tax. Kyrgyzstan is not included in the list of conventions amended by the MLI (BOI-ANNX-000511, dated April 29, 2026).

Maximum deductions and key rules

Who is a resident?

Article 1, paragraph 4, governs the residence of natural persons: a) a person is considered a resident of the State in which they have a permanent home (if they have one in both States, the one in which their center of vital interests is located); b) if the State in which their center of vital interests is located cannot be determined, they are a resident of the State in which they habitually reside; c) if they habitually reside in both States, they are a resident of the State of which they are a national; d) if they are a national of both States, the competent authorities shall decide by mutual agreement. Article 4 of the text does not deal with residence: it concerns permanent representations.

Exchange of information: what the convention does not cover

According to the BOFiP website, this convention "does not contain a clause providing for the exchange of information relating to the application of domestic legislation." Article 16 provides for exchanges, within the limits of each State's national legislation, for the application of the convention.

The 183-day rule: calendar year, permanent representation

Article 9 § 1 sets out three cumulative conditions: a stay of no more than 183 days in total during the calendar year, an employer who is not resident in the other State, and an expense not borne by a permanent representation that the employer has in the other State.

What this page does not cover

Substantial shareholdings (protocol), details of the bank interest regime, public pensions, and application to the French wealth tax (IFI) are not covered. Kyrgyz law is not addressed; its validity should be verified with a local professional.