No tax treaty between France and the Seychelles: what this means for you

The official list of French tax treaties, published in the BOFiP (Official Bulletin of Public Finances), contains no entry for the Seychelles. The list published by the Seychelles tax authorities also omits France. In practical terms, no reduced tax rates or tie-breaking rules are derived from any treaty, and the instructions for form 2047 do not provide any tax credit for income from securities held in a country without a treaty. This page presents what we have read from both sources and explains what it does not cover.

No convention in the BOFiP list, France absent from the SRC list

The SRC's pages do not provide the same breakdown of its network: a count of the lists on the agreements page yields 29 double taxation treaties and 11 information exchange agreements, while the international taxation page mentions a network of 45 jurisdictions, including 28 treaties and 13 exchange agreements. We are not making a definitive judgment on this point; it should be verified with the SRC.

The cross on the last line is illegible in the text we were able to consult; we therefore do not consider it significant. We have not read the text of any agreement, nor its date. The SRC also indicates that the Seychelles applies the Common Reporting Standard, with an initial exchange of information initiated in 2017.

The Seychelles are also not among the 11 states on the French list of non-cooperative states and territories included in this annex (decree of 15/04/2026). This list is valid on the date of your departure.

Seychelles withholding tax on payments to non-residents

The SRC publishes a withholding tax on interest, dividends, royalties, technical and management service fees, and natural resource payments made to a non-resident for Seychellois sources, with rates that vary depending on the nature of the payment. The payer withholds the tax and remits it no later than the 21st of the following month. This is a final tax.

The SRC website does not define the concept of resident. Therefore, we cannot tell you how the Seychelles administration classifies you: this is something you need to verify locally.

Withholding tax of 15 % on a Seychelles dividend: numerical example (fictitious profile)

Situation. A French citizen (fictitious profile), tax resident in France, holds shares in a Seychelles company. The company pays him a dividend of €20,000. Amounts are assumed to be in euros for clarity.

Issue. He plans to deduct from his French tax the amount withheld in the Seychelles.

Strategy. He applies the withholding tax of 15 % read at the SRC. He then declares the dividend on form 2047 for its net amount after tax withheld abroad, as provided for in the instructions for income from securities of a State without a treaty.

Result. Seychelles withholding tax: €3,000.00. Amount declared in France: €17,000.00. The €3,000.00 does not entitle you to any tax credit. The French tax due on the €17,000.00 depends on your individual circumstances and is not calculated here. The amounts are hypothetical.

No tax credit for Seychelles withholding

The decisive factor is your tax residence. If it is in France, the BOFiP (Official Bulletin of Public Finances) reminds us that income earned abroad is taxable "even if it has not been transferred to France." For a country without a tax treaty, the 2026 income tax guide states: "In the absence of a tax treaty, income is taxable in France," "without eliminating potential double taxation in France." The 2047 information sheet makes the same point for income from securities: no tax credit, net return after foreign tax.

If your tax liability is outside France, your French tax liability is limited to French-source income, subject to applicable tax treaties. None are listed here. Income received in 2025 is subject to a minimum rate of 20% (%) up to €29,579 and 30% (%) above that amount, with an option to use the average rate when it is more favorable; this option requires declaring both French and foreign income for the entire household.

French residency and Seychellois residency: who decides?

Under French law, a single criterion chosen from three categories (personal, professional, economic) determines tax residence. A stay of more than six months in the year is considered primary residence, with the caveat that it is not an absolute criterion.

With a tax treaty, its definition of residency takes precedence over domestic law. Without a treaty, your French criteria remain your only consideration. Furthermore, none of the pages consulted define Seychellois tax residency. Before setting a departure date, have your case reviewed.

Exit tax: Seychelles removed from the automatic deferral list

This applies to taxpayers who remained domiciled in France for at least six years during the ten years preceding the transfer, and who hold either at least 50% of the profits of a company, or securities worth more than €800,000 according to the information sheet ("at least €800,000" according to the information sheet: if you are close to the threshold, have it checked). The tax brackets are as follows: 12.8% income tax; social security contributions of 17.2% for a transfer in 2025, and 18.6% for a departure in 2026.

A transfer to the European Union or to one of the 70 countries listed in form 2074-ETD for transfers from January 1, 2025, automatically triggers a deferral of payment. The Seychelles are not on this list. A deferral must then be requested, which requires a tax representative established in France and security equal to 12.8% of the total capital gains and receivables.

Holding onto your shares entitles you to a tax reduction: after 2 years if their total value is less than €2.57 million, and after 5 years if it exceeds this amount. The information notice changes annually: reread the one for your departure.

Formalities to complete and Seychellois accounts to declare

Upon your departure: notify the tax authorities of your new address, and declare your income from January 1st to your departure date on form 2042 (foreign-source income on form 2047). Then, complete form 2042-NR for French-source income taxable in France only. The French Wealth Tax (IFI) is then handled by the Non-Resident Tax Office, and the official website advises you to contact your local tax authority for further information.

Each year, a resident of France must declare their accounts, life insurance or capitalization contracts, and digital asset accounts opened, held, used, or closed abroad, using form 3916 or 3916-bis. Failure to declare incurs a fine of €1,500 per account. A fine of €10,000 is cited for countries without a tax treaty; the texts consulted do not include the Seychelles, a point to verify before filing.

What this page does not cover

This document does not address Seychellois tax residency, local taxation of capital gains, inheritances and gifts, or taxes for employees and entrepreneurs living in the Seychelles. These points could not be confirmed with an official source or are covered on a separate page. They should be verified with a professional based in the Seychelles.

What changes depending on your situation

• Your address: a French criterion met, and the date of your departure.
• The nature of your income: dividends, interest, royalties, rents, capital gains.
• The value of your securities, if you own a company: exit tax, deferral, tax relief.
• Your foreign accounts and their declaration.
• Seychelles law, which this page does not deal with.

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