No tax treaty between France and Peru: Peruvian withholding taxes and no tax credit

Peru is not included in France's official list of tax treaties (BOFiP, version of April 29, 2026). For Peruvian income received by a French resident, the consequence is clear from the tax authorities: no tax credit for tax paid in Peru, and no elimination of double taxation in France. For French income received by a Peruvian resident, no treaty reduces French withholding taxes. On the Peruvian side, SUNAT (the Peruvian tax authority) levies withholding taxes on non-residents: 5 % on dividends and 30 % on royalties. This page does not provide the Peruvian tax rates for residents or the criteria for establishing Peruvian residency, which we were unable to access.

What the French lists show

The exact nature of the administrative assistance tool is therefore not established here. We do not deduce it from the cross.

Peruvian detentions on a non-resident

SUNAT publishes a table for non-resident individuals based on Article 54 of the Income Tax Law. The page is undated (footer "1997 – 2022 SUNAT"), except for the note "tasa vigente a partir del 01.01.2017" for the sale of real estate.

A second page of the SUNAT regulations concerning non-residents indicates withholding taxes of 5 % on the sale and rental of real estate, and 30 % for fourth-category income (after deducting 20 % from income) and fifth-category income. It also mentions a rate of 5 % on capital gains from the sale of Peruvian-sourced securities liquidated by a clearing institution: this is not the same as the line in the table above (securities sold outside the country, 30 %). Verify these rates in the current regulations before making any decisions: the page does not include an update date.

When Peru considers you non-resident

The above deductions apply to non-residents. SUNAT describes how one becomes non-resident: a foreigner who had a residence in Peru becomes non-resident if they are absent for more than 183 calendar days in any 12-month period. A Peruvian becomes non-resident if they have acquired residency in another country and left Peru. Resident status is restored upon return, unless the stay is 183 days or less in any 12-month period. The page does not explain how a foreigner becomes resident upon arrival: this criterion is not established here.

No tax credit in France for Peruvian tax

The 2026 income tax guide states: 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 (2025 income), in the section dedicated to income from securities, make the same point: income originating in a country without a treaty does not entitle the taxpayer to any tax credit. It must be declared net of tax withheld abroad, or gross if no tax has been withheld.

For a Peruvian dividend, the instructions therefore do not provide for any tax credit for the withholding tax paid in Peru. Form 2047 is the declaration of income from foreign sources or received abroad.

What France considers important if you reside in Peru

No convention is listed for Peru: the page therefore does not mention any more favorable conventional provision.

Leaving France: extension of exit tax and accounts

Form 2074-ETD lists 70 countries for which the deferral of exit tax payment is automatic for transfers in 2025, in addition to the member states of the European Union. Peru is not included. The form provides for a deferral for countries not listed, upon express request: a representative established in France, with security equal to 12.8% of the total capital gains and receivables. The exit tax applies to taxpayers domiciled in France for at least six of the ten years preceding the transfer, who hold at least 50% of the profits of a company or securities with a total value exceeding €800,000 (form) or "at least €800,000" (fact sheet): the two texts differ on the details, so have your file checked if you are close to this threshold.

Accounts and contracts held abroad must be declared annually (forms 3916 or 3916-bis), with a penalty of €1,500 per undeclared account. The tax authorities also mention a €10,000 penalty for an account located in a country that has not signed a tax treaty with France to combat tax fraud and evasion. The text provided does not specify how this amount applies to Peru: verify this before filing your declaration.

Peruvian dividend of €10,000 received by a resident of France: a numerical example (fictitious profile)

Situation. A Frenchman, a fictitious profile, remains domiciled in France. He holds shares in a Peruvian company, which pays him €10,000 in dividends, expressed in euros for simplicity.

Issue. He is counting on a tax credit in France for the Peruvian withholding tax.

Strategy. He applies the SUNAT rate of 5 % for a non-resident, then reads the 2047 notice to find out how to declare.

Result. Peruvian withholding tax: €500.00. French tax credit: €0. Amount to be entered on form 2047, net of foreign tax as per the instructions: €9,500.00. French tax due on this amount is not calculated here. The figures are fictitious, and the rate shown in 5 % is from an undated page.

What changes depending on your situation

• Your tax residence, in France or Peru, and the date of your departure.
• The nature of your income: dividends, interest, royalties, capital gains, salaries.
• The control of Peruvian rates in the current text.
• The value of your securities, if you hold a company: exit tax, deferral, tax relief after 2 years (total value less than 2.57 million euros) or 5 years.
• Peruvian law, which this page only partially covers: have it validated by a local professional.

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