The France-Zimbabwe tax treaty: what the 1993 text says

The tax treaty between France and Zimbabwe was signed in Paris on December 15, 1993 and entered into force on December 5, 1996. It covers taxes on income, capital gains and wealth.

A text from 1993, applied since 1996

The BOFiP (BOI-INT-CVB-ZWE, version of 12/09/2012) indicates approval by Law No. 95-1224 of 16 November 1995 and publication by Decree No. 97-233 of 10 March 1997. List BOI-ANNX-000306 (29 April 2026) classifies it as "IR – IF" (Income Tax – Wealth Tax), without amendment, inheritance, or gift tax. According to Article 29, it applies to withholding taxes since 5 December 1996, to other income taxes since 1 January 1996, and to wealth taxes since 1 January 1997.

Dividends: 10, 15 or 20 % depending on the source state

Article 10, paragraph 2, caps the tax payable by the state of the company at 10% of the gross amount for a company, other than a partnership, that directly holds at least 25% of the capital; otherwise, it is capped at 15% if the source is France and at 20% if it is Zimbabwe. Paragraph 3 allows a resident of Zimbabwe to claim a refund of the withholding tax paid in France. The protocol sets a three-year period from the date of deduction for the refund of excess withholding tax (Articles 10, 11, and 12).

Interest and royalties: 10 %, except where exempt

Articles 11, paragraph 2, and 12, paragraph 2, cap the tax levied by the State of source at 10,130 of the gross amount. Article 11, paragraph 3, specifically exempts interest where the beneficial owner is the other State or one of its entities, and interest on loans "guaranteed, insured, or subsidized" by the State concerned or certain of its entities. For Zimbabwe, the loan must be for development purposes recognized by its competent authority. Article 12, paragraph 3, classifies as royalties payments to any person other than an employee of the debtor for technical, administrative, managerial, or advisory services, provided that these services are rendered in the State of which the debtor is a resident.

Employees: 183 days over twelve consecutive months

Article 15, paragraph 2, exempts remuneration for employment in another State subject to three cumulative conditions: a stay of no more than 183 days in total during any period of twelve consecutive months, an employer who is not a resident of that State, and the remuneration not being borne by a permanent establishment or fixed base. The period is rolling, not the calendar year.

Maximum deductions and key rules

France: a tax credit, with a cap

For France, Zimbabwean tax is not deductible from income: Article 23 § 1 a) grants a tax credit against French tax. For income covered by Articles 10, 11, 12, 13 §§ 1 and 2, 16, 17 and 18, and Article 24 § 3 (second sentence), this credit corresponds to the Zimbabwean tax paid, without exceeding the corresponding French tax. For other income from Zimbabwean sources, it is equal to the corresponding French tax. Article 23 § 1 d) applies the same limit to wealth. According to point 3 of the Protocol, the corresponding French tax is the net income multiplied by the tax rate actually applied, or, under the progressive tax scale, by the ratio between the tax due on total net income and that income.

Dividend limits of 10,000: numerical example (fictitious profile)

Claire, a fictitious profile, residing in France, receives €10,000 (assumed amount) in gross dividends from a Zimbabwean company, without holding 25,130 shares of the capital. The ceiling under Article 10 § 2 is 20,130 shares, or €2,000; it would be 10,130 shares, or €1,000, for a company directly holding at least 25,130 shares of the capital. This calculation provides a conventional ceiling, not the actual amount received.

What this page does not cover

It does not detail Articles 5 to 9, 14, 16, 17, 19, 20, 24, 26 to 28, nor Zimbabwe's internal taxes. Article 2 mentions the wealth solidarity tax and not the IFI (Wealth Tax): we draw no conclusions from this. Zimbabwean law is validated by consulting a local professional.

What changes depending on your situation

The type of income, your share of the capital, your days spent in Zimbabwe, and the taxes paid there. No results are guaranteed.