The 1996 France-Uzbekistan tax treaty: interest at 5% of 1 TP3T, royalties taxable in the hands of the beneficiary

The France-Uzbekistan convention caps dividends at 5 % or 10 % and interest at 5 %. For royalties, it does not specify a rate: they are taxable only in the beneficiary's country of residence, subject to paragraphs 3, 5 and 6 of Article 12. It covers income and capital.

A 1996 convention that replaced the Franco-Soviet text

Signed in Paris on April 22, 1996, along with its protocol, the convention entered into force on October 1, 2003, and applies from January 1, 2004, for withholding taxes and other taxes. According to the French Official Tax Bulletin (BOFiP) (BOI-INT-CVB-UZB), it replaces the Franco-Soviet convention of October 4, 1985. List BOI-ANNX-000306 (April 29, 2026) classifies it among the conventions on income and wealth, without amendments.

Maximum deductions and key rules

Wealth, residence and double taxation

Article 2 mentions, on the French side, the wealth tax. Its application to the IFI (French real estate wealth tax) is not established by the sources consulted.

Article 4 distinguishes between natural persons resident in both States: permanent home, center of vital interests, habitual residence, and nationality. For a company: the place of effective management.

Article 23 grants in France a tax credit capped at the corresponding French tax; Uzbekistan grants a credit equal to the tax paid in France on income or wealth, within the limit of its own tax.

Debt recovery and inheritance (Article 27 § 3)

Article 27 § 3 limits assistance in the recovery of the debt of a deceased person to the value of the estate or the property received by each.

Dividends, interest and royalties: typical case (fictitious profile)

Situation. A French company, fictitious profile, which directly owns 10 % of an Uzbek company, receives €90,000 in gross dividends, €200,000 in gross interest from a non-bank loan and €150,000 in gross royalties.

Issue. What is the maximum withholding tax?

Strategy. Articles 10 § 2 a), 11 § 2 and 12 § 1.

Result. Dividends: €4,500 (5 %), compared to €9,000 at 10 %. Interest: €10,000 (5 %). Royalties: €0, under normal conditions and without a permanent establishment in the source state (Art. 12 §§ 3 and 5). These figures are maximums stipulated by the convention, not the tax due.

What this page does not cover

Uzbek tax rates, the exchange of information, public pensions (Article 19 § 2), the amicable procedure and inheritance rights are not addressed.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income, including the bank origin of a loan.
• The capital held.
• The days spent in each state and the fiscal year.

An article should be read in light of the facts in your case; no result is guaranteed in advance.