The France-Bangladesh tax treaty: withholding tax at 10% or 15% of 13% of income tax and increased tax credit, income tax only

The France-Bangladesh tax treaty applies only to income tax. It caps dividends at 10 or 15 1 ...

A text from 1987, not on the MLI list

The administrative list (BOI-ANNX-000306, dated April 29, 2026) lists only income tax (IR) as the tax covered and makes no mention of any provisions concerning inheritance. Bangladesh is not included in the list of conventions amended by the MLI (BOI-ANNX-000511). Article 2, from the French perspective, covers income tax and corporate tax, including withholding taxes. The convention contains no articles on wealth or inheritance.

Bangladesh: Maximum Detentions and Key Rules

Dividends of €10,000: a numerical example (fictitious profile)

Situation. A Bangladesh resident company, fictitious profile, holds less than 10 % of a French company and receives €10,000 in gross dividends.

Issue. She wants to know the maximum amount that France can retain.

Strategy. She checks her holding threshold, then applies Article 10 § 2.

Result. With less than 10 % of capital, the limit is 15 %, or €1,500. With 10 % or more held directly, it would be 10 %, or €1,000. For €10,000 of interest or royalties, the limit of 10 % results in €1,000. These are maximums stipulated by the agreement, not the tax due.

The fiscal year, not a rolling twelve-month period.

Article 15 § 2 a) measures the stay "during the tax year in question" and not over twelve consecutive months. Conditions relating to the employer and permanent establishment are also included. For the self-employed, Article 14 § 1 b) requires a stay of a total duration equal to or exceeding 120 days during the tax year. The definition of the Bengali tax year is not provided here.

Article 23: an increased tax credit

For residents of France, Article 23, paragraph 2, distinguishes three situations. According to paragraph 2(a), income taxable in Bangladesh that does not fall under paragraph 2(b) is exempt in France. According to paragraph 2(b), a tax credit, capped at the French tax, applies to income from Articles 10, 11, 12, 14, 16, 17, and 22. According to paragraph 2(c), for dividends, interest, and royalties from Articles 10, 11, and 12 originating in Bangladesh, the Bangladeshi tax is considered equal to the amount withheld, plus 10% of the gross income, without exceeding 20% of the gross income. We do not calculate this mechanism; it is explained in the text, income by income.

Residence, earnings, pensions

Article 4, paragraph 2, establishes the order of priority for dual residence: permanent home, then center of vital interests, habitual residence, nationality, and agreement of the authorities. For capital gains, real estate is taxable where it is located, and other assets only in the state of the transferor (Article 13, paragraph 5). Private pensions are taxable in the state of residence; Article 18, paragraph 2, addresses separately pensions paid under the social security legislation of a state.

What this sheet does not cover

The Bengali tax, the definition of royalties beyond the rate, the protocol, public remuneration, wealth and inheritance (absent from the text) are not addressed.

What changes depending on your situation

• Your residence as defined in the agreement.
• Your percentage of ownership, direct or indirect.
• The nature of the income and the withholding rate actually applied.
• The days spent in each state during the fiscal year.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.