The 2004 France-Slovenia tax treaty: ceilings of 15 % and 5 %, and a condition of the Protocol

The France-Slovenia convention, signed in Ljubljana on April 7, 2004, caps withholding tax at 15 % for dividends and 5 % for interest and royalties. Dividends paid to a company directly holding at least 20 % of the capital for 365 days are taxable only in the recipient's country. The Protocol provides a cap of 5 % "as long as Slovenia is not a member of the European Union" for certain dividends, interest, and royalties: the page presents the sourced facts without drawing any legal conclusions. No article addresses inheritance.

A text from 2004, the MLI since 2019

Entering into force on March 1, 2007, it replaces the 1974 convention with the former Yugoslavia in relations between France and Slovenia and applies to withholding taxes on sums payable from January 1, 2008. The administrative list (BOI-ANNX-000306, of April 29, 2026) classifies it among the conventions on income and wealth, without amendment.

The MLI modifies it: the CML has been in effect since July 1, 2018 for Slovenia and January 1, 2019 for France; the BOI-ANNX-000511 list gives effects from January 1, 2019 (withholding taxes) and July 1, 2019 (other taxes). A clause placed before Article 1 denies the benefit of the convention if one of the main objectives of an arrangement is to obtain it.

Maximum deductions and key rules

The Protocol and the European Union

Three points of the Protocol begin with the same condition: "as long as Slovenia is not a member of the European Union." Point 3 caps the withholding tax on dividends under Article 10 § 2 b) at 5, point 4 caps the tax on interest under Article 11 § 3 c), and point 5 a caps the tax on royalties under Article 12 § 4. Sourced facts: Slovenia joined the European Union in 2004, according to the website diplomatie.gouv.fr, and the convention has been in force since March 1, 2007, according to the BOFiP (French Official Tax Bulletin). The Protocol does not specify the implications of points 3, 4, and 5 a), and we draw no conclusions from them: the scope of these points should be verified with an official source before any calculations are made.

Point 5 b) separates remuneration for technical services (analyses, studies, engineering, consulting, monitoring): these are not royalties and fall under Article 7.

Residence and disposal

Residence. Article 4 § 2 distinguishes in order: permanent home (failing that, the closest personal and economic ties), habitual residence, nationality, agreement of the authorities.

France. Article 23 provides for a tax credit against French tax, up to the amount of the corresponding French tax. Slovenia grants a deduction equal to the income tax paid in France, capped at the corresponding portion of Slovenian tax.

Royalties of €80,000: numerical example (fictitious profile)

Situation. A French company, fictitious profile, pays €80,000 in gross royalties to a Slovenian company, without holding 20 %.

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

Strategy. It applies Article 12 § 2, then verifies the possession and scope of the Protocol.

Result. The ceiling is €4,000 (€80,000). For €100,000 of gross dividends falling under Article 10 § 2 a), it would be €15,000 (€15). These are maximums, not the tax due.

What this page does not cover

It does not address Slovenian taxes, self-employment, or the French wealth tax (IFI): Article 2, paragraph 3, lists the wealth tax, and, according to paragraph 4, the convention also applies to taxes of the same or similar nature. The IFI is not mentioned, and we draw no conclusions from this. The convention contains no article on inheritance.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income and the ownership rate.
• The scope of the Protocol as of the date of your operation.
• The number of days spent in each state over twelve consecutive months.

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