France and the Dominican Republic: the absence of a tax treaty, point by point

The Dominican Republic is not included in France's administrative list of tax treaties. Each country therefore applies its own domestic law, without any provisions for allocating taxation between them. In the Dominican Republic, the Código Tributario (Tax Code) withholds 10% of the tax on dividends, regardless of whether the recipient is a resident or not (Article 308), and 10% of the tax on interest paid to non-residents (Article 306). In France, a person domiciled in France is taxed on their worldwide income. This page addresses these two domestic legal systems and explains what they do not cover.

An official list without a Dominican line

The BOI-ANNX-000306 doctrine, in its version of April 29, 2026, contains no entry for the Dominican Republic. It specifies that it applies to conventions in force on January 1, 2026, and refers to the "Treaties and Agreements" database for other agreements. Since the list contains no entries, it also does not include entries for inheritances and gifts.

Two points further illustrate this observation. The Dominican Republic is not included on the French list of non-cooperative states and territories, which has comprised 11 states since the decree of April 15, 2026. However, it does appear, as "Dominican Republic X," in the appendix to the 2027 draft budget law, which lists the states that have concluded an administrative assistance agreement with France in force as of September 1, 2026. The column marked with a cross is not legible in the excerpt we have: we therefore draw no conclusions about the nature of the text.

Two internal laws, no article to distinguish between them

French side, Only one criterion from Article 4 B of the French General Tax Code (CGI) is required: primary residence or place of residence, principal activity, or center of economic interests (BOI-IR-CHAMP-10, § 220, § 230 and § 310). A stay of more than six months "does not constitute an absolute criterion" (§ 150). The French Official Tax Bulletin (BOFiP) indicates that these rules apply only subject to tax treaties (BOI-INT-DG-20-10-10, § 20).

Dominican side, Article 12 of the Tax Code declares residents for tax purposes those persons who reside in the country for more than 182 days during the tax year, whether continuously or intermittently. Domicile can also be the place of habitual residence, principal activities, or the principal place of business.

The two tests are separate. The same person can take both, and there is no article here to help you choose. Our page on living in the Dominican Republic details the 182-day test.

What the Dominican Republic withholds at the source

Title II of the Dominican Tax Code, as published by the Dominican tax administration (DGII), sets out the following withholdings on income from Dominican sources:

Article 270 subjects non-residents to tax only their income from Dominican sources. With a permanent establishment, the income attributable to that establishment is taxed as if it were from a local company.

An exception is provided in paragraph I of Article 308: dividends distributed within the limit of the dividend account are excluded from this withholding.

Dominican deductions from a local portfolio: a numerical example (fictitious profile)

Situation. A fictitious French resident holds securities and a debt in the Dominican Republic. During the year, she receives, in Dominican pesos, 1,000,000 RD$ in dividends, 500,000 RD$ in interest, and 2,000,000 RD$ from another annuity of Dominican origin.

Issue. She wants to know the amount withheld there before even declaring anything in France.

Strategy. She associates each income with its article: 308 for dividends, 306 for interest, 305 for the other annuity.

Result. The withholding tax on dividends is 100,000 RD$, resulting in a net tax of 900,000 RD$. The withholding tax on interest is 50,000 RD$, resulting in a net tax of 450,000 RD$. The other annuity, taxed at 27 % according to Article 297, is subject to 540,000 RD$, leaving 1,460,000 RD$. The total withheld amount is 690,000 RD$. These amounts are hypothetical. The remaining figures for the French side are not established by our sources: see below.

Dominican income received by a resident of France

A person domiciled in France is taxable on income earned abroad "even if it has not been transferred to France" (BOI-INT-DG-20-10-10, § 70). A person not domiciled in France is taxable only on their French-source income (§ 90).

We checked the BOFiP (French Official Tax Bulletin) to see if tax paid abroad entitles the taxpayer to a tax credit or deduction when there is no tax treaty. The pages we consulted on eliminating double taxation did not answer this question, except for the CSG (General Social Contribution) and CRDS (Contribution to the Repayment of the Social Debt). Therefore, this page does not resolve this issue.

On the Dominican side, article 316 allows residents to credit income tax paid abroad on their foreign-sourced annuities, up to the limit of Dominican tax on those same annuities.

Declaring your accounts, measuring the exit tax

Bank accounts, assurance-vie or capitalization contracts, and digital asset accounts opened abroad must be declared annually. The fine is €1,500 per undeclared account (service-public.fr website, page verified on April 15, 2026). The same page cites a fine of €10,000 for a country without a tax treaty against tax fraud and evasion; we do not classify the Dominican Republic as such.

For a departure from France, the exit tax requires six years of tax residency within the last ten years, with securities worth €800,000 or a shareholding of at least 50% of the profits in a company. The threshold is stated in two different ways in the instructions and the information sheet. 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 18.6% for a departure in 2026. Automatic deferral is reserved for the destinations described in Form 2074-ETD; we have not reviewed the list, and the eligibility of the Dominican Republic is not established.

What this page does not cover

It does not provide the current Dominican income tax rates (Article 296 of the text we read stipulates a scale adjusted annually for inflation; we did not note the current amounts), nor the ITBIS rate, nor Dominican inheritance taxes, nor social security contributions. It does not address the French tax credit without a treaty. Dominican regulations should be verified with a professional based in the country.

What changes depending on your situation

• The type of income: dividend, interest, other annuity.
• Your residence under both domestic laws, and the number of days spent in each country.
• The existence of a permanent establishment or a local company.
• Your accounts and contracts held abroad.
• The date of your departure, if you are leaving France.

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