The France-Syria tax treaty: what the text says

The France-Syria convention was signed in Paris on July 17, 1998, and supplemented by an exchange of letters in Damascus on December 16, 2004. It entered into force on May 1, 2009, and applies only to income tax. Three rates apply: 15% for dividends, 10% for interest, and 15% for royalties. For information on penalties, see the French Treasury website cited below.

2009, 2010: two application dates

According to the BOFiP (BOI-INT-CVB-SYR, version of 12/09/2012), Law No. 2009-226 of 26 February 2009 authorized the approval, and Decree No. 2009-812 of 1 July 2009 published the text. Article 26 sets the application date: from 1 May 2009 for withholding taxes, and from 1 January 2010 for other income taxes. The list of 29 April 2026 (BOI-ANNX-000306, agreements in force on 1 January 2026) includes the convention with the mention "IR" alone: neither wealth nor inheritance tax. Syria has no entry in the list of conventions amended by the MLI (BOI-ANNX-000511, same date). The BOFiP commentary, in its 2012 version, does not mention suspension or denunciation and says nothing about the current status of the agreement.

Dividends: 15 %, or Beneficiary's State from 10 % of the capital

Article 10 § 2 a sets the limit at 15 % of the gross amount. Article 10 § 2 b waives this limit when the beneficial owner is a company that holds, directly or indirectly, at least 10 % of the capital of the paying company: the dividends are then taxable only in the State of which this beneficial owner is resident.

Royalties: an article added in 2004

The exchange of letters dated December 16, 2004, inserted Article 11 A between Articles 11 and 12. Paragraph 2 of this article caps the withholding tax at 15% of the gross amount of royalties. It also corrected references to Articles 21 and 22.

Maximum deductions and key rules

Who is a resident?

Article 4 § 2 applies to a natural person resident in both States. It considers, in order: the permanent home (then the center of vital interests), the habitual residence, the nationality, and finally the agreement of the competent authorities.

Tax credit: two systems depending on income

For France, Article 21 § 1 a provides for two cases. For income not mentioned in point ii, the credit is equal to "the French tax corresponding to this income," provided that the French resident is subject to Syrian tax on this income. For dividends, interest, and royalties (Articles 10, 11, and 11 A) and other listed income, the credit is equal to the tax paid in Syria, with this limit: "this tax credit may not exceed the amount of French tax corresponding to this income.".

Taxes concerned

Article 2, paragraph 3, cites "in particular," for France, income tax, corporation tax, and payroll tax. For Syria, it cites five categories, including tax on industrial, commercial, and non-commercial profits, tax on salaries and wages, and tax on income from movable and immovable property.

Sanctions: what the Treasury Directorate General says

According to the French Treasury's "Syria" page, published on March 19, 2026, the European Union eased its sanctions after December 8, 2024, and almost all sectoral sanctions were lifted (energy, transport, and the financial sector, in particular). The page specifies: "However, certain sectoral restrictions remain in effect," notably for equipment that could be used for internal repression, dual-use goods, items on the Joint Military List, certain technologies and software, and Syrian cultural property. Some asset freezes remain in place. No legal conclusions are drawn here; see the source cited at the end of the page.

What this page does not cover

The articles not cited above, the protocol, the exchange of information (Article 24), and Syrian law are not detailed. The current status of the convention is not addressed here; this should be verified with the relevant authorities.

Typical case (fictitious profile)

A company holds shares in a French company and receives dividends. Everything depends on the shareholding: at 10% or more of the capital, the dividends are taxable only in the recipient's country (Article 10 § 2 b); below this threshold, the 15% limit applies (Article 10 § 2 a). No amount is calculated.