No tax treaty between France and Liechtenstein: an information exchange agreement, not a treaty.

France does not have a tax treaty with Liechtenstein: the principality is not listed in the official BOFiP (Official Bulletin of Public Finances). However, the two states are bound by an information exchange agreement, in effect since August 19, 2010. For a French tax resident, income from Liechtenstein sources remains taxable in France, and the tax paid there does not entitle the taxpayer to a tax credit. On the Liechtenstein side, the tax law does not provide for withholding tax on dividends. This page does not cover foundations, companies, or inheritances.

A list without Liechtenstein, a swap agreement in place since 2010

The French tax authorities (BOFiP) have published appendix BOI-ANNX-000306, "List of tax treaties concluded by France," which came into force on April 29, 2026. This appendix only lists agreements in force on January 1, 2026. Liechtenstein is not included. The list makes no mention of agreements signed but not yet in force on that date.

The annex to the 2027 draft budget law concerning France's information exchange network contains a table of states with administrative assistance agreements in force as of September 1, 2026. The entry for Liechtenstein reads: "Information exchange agreement entered into force on August 19, 2010." This is an information-sharing tool between government agencies. The document does not derive any tax allocation rules from it.

Liechtenstein is also not on the French list of non-cooperative states and territories. This list includes 11 states and territories as of the decree of April 15, 2026. It is valid as of the date of your decision.

Liechtenstein income of a French resident: taxable in France, without tax credit

A French tax resident is domiciled in France within the meaning of Article 4 B of the French General Tax Code (CGI). The French Tax Administration's Official Bulletin (BOFiP) considers the home or principal residence, professional activity, and center of economic interests. Only one criterion is required. More than six months of residence is not an absolute criterion.

The practical guide to income tax states: "In the absence of a tax treaty, income is taxable in France." It adds that without a treaty, France does not eliminate double taxation. For securities, the instructions for form 2047 (income tax return 2025) specify that income from a country without a treaty does not entitle the taxpayer to any tax credit. This income must be declared net of any tax withheld abroad. If no tax has been paid locally, the gross amount is reported on form 2047.

This notice concerns income from securities. Liechtenstein salaries or attendance fees fall under a different category; this page does not cover them.

What Liechtenstein withholds at the source

The relevant legislation is the Steuergesetz (SteG), the law of September 23, 2010, on state and municipal taxes, as amended on July 1, 2026, and based on the official laws of the Principality. Individuals who are neither domiciled nor habitually resident in Liechtenstein are taxed solely on their assets and income from Liechtenstein sources (Art. 6 para. 2). Habitual residence is defined as more than six consecutive months (Art. 2).

The last line is a reading observation: neither dividends nor interest are listed in Article 24 of the SteG (German Tax Code). Other texts, not consulted here, may exist. Therefore, for a Liechtenstein dividend received by a French resident without withholding tax, form 2047 requires the gross amount.

French shares held from Liechtenstein: a numerical example (fictitious profile)

Situation. Marc, a fictional character, resides in Liechtenstein and is taxed there on all his wealth and income. He owns shares in French companies, valued at CHF 2,000,000 at the beginning of the year (hypothetical). These companies pay him a gross dividend of €60,000 (hypothetical).

Issue. He wants to know what France is holding back, and what Liechtenstein is asking of him.

Strategy. He notes that France has no tax treaty with Liechtenstein: no reduced treaty rate applies. The withholding tax on a dividend of French origin paid to a non-resident is 12.80 %, the rate in effect as of January 1, 2026. In Liechtenstein, profit shares on equity investments are exempt from income tax (Art. 15 para. 2 let. n, subject to the limitations of the text). However, wealth is used to calculate a standardized return of 4 % (Art. 5), which is included in taxable income. Wealth amounts are rounded down to the nearest hundred francs (Art. 18).

Result. The French withholding tax is €7,680, and the net dividend is €52,320. The standardized yield is CHF 80,000 (4 % of CHF 2,000,000). At the general rate of Article 19, in the bracket from CHF 73,991 to CHF 105,700 (0.05 · x − 1,744), the tax is CHF 2,256. This figure excludes the municipal surcharge, the rate of which could not be determined, as well as the deductions and exemptions under Article 10. The dividend itself is not included in this tax base.

One point remains unresolved: Article 22, paragraph 2 of the German Tax Code (StEG) provides for the crediting of foreign tax when a double taxation agreement so provides, or in the case of reciprocity ("bei Gewährung von Gegenseitigkeit"). No such agreement with France is listed in the French Official Tax Bulletin (BOFiP). The text as read does not clarify whether the French withholding tax is credited to Liechtenstein. This point should be verified with a local professional.

French income of a resident of Liechtenstein

A non-resident is taxed in France only on their French-source income, subject to tax treaties. The minimum rate is 20% of income up to €29,579 and 30% of income above that amount, for income received in 2025. They can claim the average rate if it is more advantageous, by declaring all household income. Since no tax treaties are listed for Liechtenstein, no treaty reductions are mentioned here.

Accounts and contracts: declaration 3916 remains due

Any account opened, used, held, or closed abroad must be declared annually using form 3916 or 3916-bis, attached to the income tax return. The penalty is €1,500 per undeclared account, according to the tax authorities' website. The website stipulates a penalty of €10,000 if the account is located in a country without a tax treaty with France. The website does not specify whether the information exchange agreement falls into this category; therefore, the amount applicable to a Liechtenstein account is not indicated here.

Dual residence: what this page does not address

The tax treaties categorize dual residents according to a specific order: permanent home, closest personal and economic ties, habitual residence, and nationality. The BOFiP (Official Bulletin of Public Finances), which describes this, does not explicitly address the case without a tax treaty. Therefore, the page does not explain how to determine dual residence in France and Liechtenstein. The SteG (State Tax) only establishes the Liechtenstein rule: domicile or habitual residence of more than six months.

What changes depending on your situation

• Your tax residence: France, Liechtenstein, or a situation in between.
• The nature of the income: dividend, salary, tokens, pension, rent.
• The country where the income is paid and the amount withheld at source.
• Accounts or contracts held in Liechtenstein must be declared in France.
• The date of your decision: the list of non-cooperative states and the rates are verified on this date.

The rule depends on your situation. No results are guaranteed.

What this page does not cover

This section does not cover Liechtenstein foundations or companies, inheritance tax, residence permits, or the municipal surcharge, the rate of which could not be determined. Local tax matters should be verified with a Liechtenstein tax professional. French tax matters are addressed in our sections on tax residency, tax return 2047, and form 3916.