No tax treaty between France and the Maldives: a withholding tax of 10% (%), without French tax credit on investment income.

France does not have a tax treaty with the Maldives: the administrative list of April 29, 2026, contains no entry for this country. In practical terms, dividends, interest (except interest paid to a bank or a non-bank financial institution authorized by the MIRA), royalties, or rent paid from a Maldivian source to a non-resident is subject to a withholding tax of 10%. For income from securities and movable capital, the French tax authorities do not grant any tax credit: the income is declared net of the withholding tax. This page describes these two rules and then explains what changes for those leaving the country.

What the official list says

The BOI-ANNX-000306 doctrine, in its version of April 29, 2026, contains no information regarding the Maldives. It specifies that only agreements and conventions in force on January 1, 2026, are listed. This omission should be verified before any decision is made.

The annex to the 2027 draft budget law on administrative assistance contains a line item for "Maldives" followed by a cross. We do not know in which column this cross falls, and we have not read any agreement text: it serves no purpose here. The Maldives are not included on the French list of non-cooperative states and territories, which has included 11 states since the decree of April 15, 2026.

The Maldives withholds 10 % at source on most non-resident income

The Maldivian Revenue Authority (MIRA) describes a withholding tax on non-residents, the Non-Resident Withholding Tax. Businesses operating in the Maldives must withhold and remit this tax.

Two rules on the page are useful. Withholding tax is the recipient's "final" tax when the income is not attributable to a permanent establishment, or when filing a tax return is not possible. Rental income from Maldivian properties is among the types of income for which the recipient can choose to file a return. The page does not specify any thresholds.

Capital gains tax in the Maldives: the tax is levied on the gross price

For a non-resident, the sale of real estate located in the Maldives is subject to a separate withholding tax, the Capital Gains Withholding Tax. It also applies to shares in an entity whose value is more than 50% attributable to Maldivian real estate, shares in a resident company or partnership, and certain intangible assets used in the Maldives.

The rate is 10 %, applied "to the gross payment" by the withholding agent who files the return (form MIRA 608). The withholding is therefore calculated on the price, not the profit. The page does not state whether this exempts the seller from any further taxation; we do not assert this.

Who is a non-resident in the Maldives

The tax classification determines the application of these withholdings. A resident is someone whose permanent residence is in the Maldives, or who is present there, or plans to be there, for more than 183 days within a 12-month period beginning or ending in the tax year. A foreigner authorized to stay under the Immigration Act, and not married to a Maldivian citizen, is then considered a "temporary resident": they are taxed only on their Maldivian-source income. Anyone who is neither a resident nor a temporary resident is considered a non-resident.

No French tax credit on investment income held in the Maldives

The practical guide to income tax for 2026 is clear: in the absence of a tax treaty, income is taxable in France, without any elimination of potential double taxation in France. The instructions for form 2047 (income for 2025) specify, for securities and movable capital, that income originating in a country without a treaty does not entitle the taxpayer to a tax credit. This income must be declared, if applicable, for its net amount after tax withheld abroad (section 2, lines 220 and 250). Without withholding, the gross amount is entered on form 2047.

This rule applies to investment income. We have not found an equivalent rule for rents or capital gains on real estate: it does not extend to these types of income.

Maldivian dividend of 100,000: numerical example (fictitious profile)

Situation. A person domiciled in France holds a stake in a Maldivian company. They receive a gross dividend of 100,000 (assumed equivalent in euros).

Issue. She wants to know what happens to the Maldivian withholding tax in her French tax return, since no agreement exists.

Strategy. She applies the two texts read: withholding of 10 % from MIRA, then declaration on form 2047 for the net amount, without tax credit.

Result. The withholding tax is 10,000 and the declared dividend is 90,000. The 10,000 does not generate any tax credit in France. The calculation stops there: the French tax rate applicable to this 90,000 is not addressed and depends on the individual's circumstances. For a property sale of 500,000 by a non-resident, the Maldivian withholding tax would be 50,000, calculated on the price and not on the capital gain.

French tax residence does not yield to any tie-breaker clause.

Article 4 B of the French General Tax Code (CGI) establishes personal, professional, and economic criteria. Only one of these criteria is sufficient (BOI-IR-CHAMP-10, § 70 and § 310). A stay of more than six months "does not constitute an absolute criterion" (§ 150). Domestic rules apply only subject to tax treaties (BOI-INT-DG-20-10-10, § 20): without a listed treaty with the Maldives, no article differentiates between a French domicile and a Maldivian residence. A person domiciled in France is taxed on their foreign-source income, even if not repatriated (§ 70). A person domiciled outside France is taxed only on their French-source income (§ 90).

Exit tax for departure to the Maldives

The exit tax applies to individuals domiciled in France for at least six of the last ten years, holding securities with a total value of €800,000 or a shareholding of at least 50% of the profits in a company. Form 2074-ETD and the tax authorities' information sheet do not define the threshold in the same way: "greater than" in one case, "at least" in the other. Form 2074-ETD provides a flat rate of 12.8% for income tax on transfers occurring in 2025. We have no source for this rate regarding departures in 2026: it should be verified with the tax authorities. Social security contributions are 17.2% for transfers in 2025 and 18.6% for departures in 2026.

According to form 2074-ETD (case no. 1), deferral of payment is automatic for transfers to a Member State of the European Union or to a State that has concluded with France an administrative assistance agreement for combating tax fraud and evasion, as well as a mutual assistance agreement for tax recovery, and which is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). The form lists the States concerned. We were unable to establish that the Maldives meet these conditions. Otherwise, the request must be made within 90 days before departure, although the wording differs in the two texts. The tax relief is granted after two years if the securities are worth less than €2.57 million, and after five years if they are worth more than €2.57 million.

Initially: declarations and accounts

The official website requires reporting your new address, declaring income up to your departure date on form 2042 (foreign sources on form 2047), and reserving form 2042-NR for French-source income from your departure until December 31st. The French Wealth Tax (IFI) falls under the SIP-NR (French Taxpayer Identification Number). Bank accounts, life insurance policies, and digital asset accounts opened abroad must be declared annually: a €1,500 fine per undeclared account (service-public.fr website, page verified on April 15, 2026). The same page mentions a €10,000 fine for a country without a tax treaty against tax fraud and evasion: we do not classify the Maldives.

What this page does not cover

This document does not address the Maldivian tax rate for residents, VAT, social security, or visas (see the companion page on taxation and residency in the Maldives, to be published alongside it). It makes no mention of Maldivian wealth or inheritance taxes: none of the sources consulted discuss them. Nor does it explain how French tax applies to Maldivian rental income or capital gains. These points should be verified with a professional based in the Maldives.

What changes depending on your situation

• The type of income: dividend, interest, royalty, rent or capital gain.
• Your status in the Maldives: resident, temporary resident or non-resident.
• Votre domicile fiscal à la date du départ et la durée de votre domicile en France.
• The nature and value of your securities, and the deferment applicable to your destination.

No result is guaranteed in advance.