The France-Slovakia tax treaty: the 1973 text signed with Czechoslovakia

Tax relations between France and Slovakia are based on the convention signed in Paris on June 1, 1973, with Czechoslovakia. This convention caps withholding tax at 10% for dividends and 5% for royalties, reserves interest for the country of the beneficiary, and covers income and wealth taxes. Copyright royalties for literary, artistic, or scientific works are taxable only in the beneficiary's country of residence (Article 13, § 3). The convention contains no provisions on inheritance. This page presents the articles found in the consolidated text.

From Czechoslovakia to Slovakia

The convention entered into force on January 25, 1975. It ceased to apply to the Czech Republic on July 1, 2005, the date of entry into force of the Franco-Czech convention. An exchange of letters signed in 1996 (Decree No. 98-845 of September 16, 1998) stipulates that it continues to have full effect with respect to Slovakia. The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it among the conventions on income and capital, without amendment.

The consolidated text names Czechoslovakia in Article 3; the tax authorities present it as applicable between France and Slovakia. The MLI (Mission Laïque Française) amends it: the BOI-ANNX-000511 list gives it effect from January 1, 2019, for withholding taxes and from July 1, 2019, for other taxes. A clause at the beginning of the text denies the benefit of the convention if one of the main objectives of a tax arrangement is to obtain it.

Maximum deductions and key rules

Residence and earnings

Article 4, paragraph 2, categorizes individuals according to the following criteria: permanent home, center of vital interests, habitual residence, nationality, and then amicable agreement. Article 14 stipulates that shares in companies where more than 50% of the value derives from real estate are taxable in the State where the real estate is located, based on the 365 days preceding the transfer.

Exemption in France, tax credit for four items

Article 25A stipulates that France exempts income taxable in Czechoslovakia under the convention, except for income covered by Articles 10, 13, 17, and 18. For these latter incomes, France grants a tax credit equal to the tax levied in Czechoslovakia. Pensions (Article 19) and capital gains (Article 14) are not included in this list of exceptions.

Royalties of €50,000: numerical example (fictitious profile)

Situation. A French company, fictitious profile, pays €50,000 in gross royalties to a Slovak company, excluding copyright on literary, artistic or scientific works (Article 13 § 3).

Issue. She wants to know the maximum tax withheld in France.

Strategy. It applies the ceiling of Article 13 § 2, then verifies the residence of the beneficial owner and the clause entitling them to benefits.

Result. The ceiling is €2,500 (5 % of €50,000). For €60,000 of gross dividends, the ceiling under Article 10 § 2 would be €6,000 (10 %). These are maximums, not the actual tax due.

What this page does not cover

It does not address Slovak taxes, nor Articles 5 to 9, 17 and 18, nor the details of wealth (Article 24): its application to the French Wealth Tax (IFI) is not established. Article 10 § 2 does not stipulate any holding period requirement. The term "succession" in the BOFiP (French Official Tax Bulletin) here refers to the succession of states, not the succession of persons.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income: dividend, interest, royalty, pension, salary, gain.
• The days spent in each state during the fiscal year.
• The nature and location of your possessions, for fortune.

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