Absence of a France-Nicaragua tax treaty: effects for a French resident

France does not have a tax treaty with Nicaragua: the country is not included in the official BOFiP list, which lists agreements in force as of January 1, 2026. For a French tax resident, Nicaraguan-sourced income remains taxable in France. The instructions for form 2047 stipulate that this income must be declared net of tax withheld locally, without any French tax credit. Nicaragua is also included in the list of sanctions regimes published by the French Treasury. This page summarizes these points. It does not provide any Nicaraguan tax rates: the relevant local regulations could not be consulted.

Nicaragua: Four French lists, four responses

Four official French documents help to locate Nicaragua.

Three points to clarify regarding reading.

• The absence of the BOFiP list means that no agreements are reported as of January 1, 2026. The list does not indicate whether a text has been signed but is not yet in force on that date. It specifies that, for an agreement not included in the list, the Treaties and Agreements database of the Ministry for Europe and Foreign Affairs must be consulted, which was not accessed here.
• The absence of the administrative assistance table is a noted observation. The page does not address other forms of information exchange.
• According to the annex to the 2027 Finance Bill, which refers to the decree of April 15, 2026, Nicaragua is not on the French list of non-cooperative states.

Sanctions: what the Treasury Directorate General says, and what it doesn't say

The French Treasury's website states that "the Council of the European Union and Member States may adopt restrictive financial or trade measures." It lists Nicaragua among the geographical regimes. It does not specify the origin of the regime applicable to Nicaragua, the nature of the measures, or their effect on any individual.

This page does not establish this either. Before transferring funds or opening an account, the scope of the measures should be verified by consulting the texts in the list and with the institution concerned.

An investment agreement from 1998, but no tax legislation

The "Franco-Nicaraguan Relations" page of the French Embassy (published on 19/09/2025, updated on 09/12/2025) lists 14 agreements and treaties. It includes, in particular:

• «"Reciprocal encouragement and protection of investments (February 13, 1998)"; ;
• two debt agreements dated August 30, 2004, a consolidation agreement dated April 23, 2003; ;
• the abolition of the requirement for a short-stay visa (April 20, 1999).

None of the 14 headings are tax treaties or double taxation agreements. The 1998 agreement is not read here; the page only provides its title. An investment agreement is not presented on the page as a tax text, and this page does not attribute any tax implications to it.

Law 822: the Nicaraguan text that this page does not elaborate on

The website of the Nicaraguan Ministry of Finance (Ministerio de Hacienda y Crédito Público) lists, in its "Laws" section, Law 822, "Ley de Concertación Tributaria" (Law of Tax Consultation), and specifically Laws 891, 922, 987, 1212, and 1279, presented as its reforms. The section also lists Law 339, whose title refers to the Dirección General de Ingresos ("Ley Creadora de la Dirección General de Ingresos").

The text of the law, hosted by the Nicaraguan National Assembly, could not be read: the site blocked automated reading. The website of the Dirección General de Ingresos (General Directorate of Revenue) did not provide any usable content. The text, which has been amended several times, is presented in its current version: the Nicaraguan rates, thresholds, and residency requirements are therefore not included here.

Nicaraguan income of a French resident: taxable in France

A French tax resident is domiciled in France within the meaning of Article 4 B of the French General Tax Code (CGI). The French Official Tax Bulletin (BOFiP) (BOI-IR-CHAMP-10, version of July 28, 2016) identifies three main criteria: the home or principal residence, professional activity, and the center of economic interests. Only one of these criteria is required. It also applies to government employees working abroad and includes an exception to the professional activity criterion (activity carried out on an ancillary basis). The six-month residency requirement is not an absolute criterion.

The practical guide to income tax states the following for foreign-source income: "In the absence of a tax treaty, income is taxable in France, without eliminating the possibility of double taxation in France." With a treaty, certain types of income qualify for a tax credit equal to the French tax paid. The instructions for form 2047 (income tax return for 2025), section 2, lines 220 and 250, classify income originating from a country with which France has no tax treaty as "income not eligible for a tax credit." They instruct taxpayers to declare this income net of any foreign tax withheld. If no foreign tax has been paid, the gross amount is entered on form 2047.

Nicaraguan dividend to be declared: numerical example (fictitious profile)

Situation. Hélène, a fictitious profile, is a tax resident of France. A Nicaraguan company in which she holds shares pays her a gross dividend of 20,000 (fictitious monetary unit).

Issue. She wants to know what amount to put on form 2047. She doesn't know the withholding tax rate in Nicaragua, and this page doesn't provide it.

Strategy. First, she checks for the absence of an agreement in the BOFiP list. Then, she notes on the proof of payment the amount of tax possibly levied locally, and then declares the dividend according to the rule in the instructions.

Result. Two scenarios, with hypothetical amounts. Without any local withholding, she declares 20,000 on form 2047. With a hypothetical local withholding of 2,000, she declares 18,000. In both cases, no French tax credit is applied. The 2,000 difference in the declared amount is not a Nicaraguan tax rate; it is a calculation assumption. The French tax on 18,000 or 20,000 depends on the tax brackets and Hélène's specific situation; it is not calculated here.

Bank account in Nicaragua: form 3916

Any account opened, used, or closed abroad must be declared annually using form 3916 or 3916-bis, attached to the income tax return. The tax authorities' website (published on June 25, 2026) stipulates a fine of €1,500 per undeclared account. This fine increases to €10,000 if the account is located in a country that has not signed an anti-fraud treaty with France. Nicaragua's absence from the list of countries with which tax authorities are registered is not sufficient to establish this connection. Such a connection is not established here and is verified on the date of the tax return.

French income of a person residing in Nicaragua

If a person is no longer domiciled in France, they are taxed only on their French-source income, subject to tax treaties, according to economie.gouv.fr (article dated April 24, 2026). 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 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 under tax treaties. As no treaty is reported for Nicaragua, no treaty reduction is mentioned here.

Dual residency in France and Nicaragua: what the doctrine doesn't say

The BOFiP (BOI-INT-DG-20-10-10) establishes the order of priority for tax treaty rulings for a person domiciled in both states: permanent home, closest personal and economic ties, habitual residence, and nationality. This text applies between states bound by a treaty. It does not specify a rule for situations where no treaty exists. Since the Nicaraguan residency criterion was not consulted, the page does not explain how to determine dual residency.

What changes depending on your situation

• Your tax residence: France, Nicaragua, or a situation in between.
• The nature of the income: dividend, interest, capital gain, rent.
• The amount withheld at source and the date of payment.
• Accounts or contracts held in Nicaragua must be declared in France.
• The bank that executes the transfers, in view of the list of sanctions.

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

What this page does not cover

It provides no information on Nicaraguan tax rates, local tax residency criteria, withholding tax on dividends, wealth tax, inheritance tax, social security contributions, visas or residence permits, or the nature of penalties. Local tax matters should be verified with a Nicaraguan tax professional. French tax matters are addressed in our sections on tax residency, the 2047 tax return, and form 3916.