The France-Belarus tax treaty: three articles suspended from June 1, 2024 to December 31, 2026

The tax treaty of October 4, 1985, concluded with the USSR, remains in effect with respect to Belarus, but three of its articles are suspended from June 1, 2024, to December 31, 2026: Article 7 (dividends), Article 8 (interest), and Article 11 (income from the exploitation and disposal of property). During this period, the reduced rates no longer apply.

A text from 1985, a partial suspension

The convention was signed in Paris on October 4, 1985, and entered into force on March 28, 1987. The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it for income tax purposes and notes: "Partial suspension of the convention as of June 1, 2024." Belarus is not included in the list of conventions amended by the MLI. According to the doctrine (BOI-INT-CVB-BLR, version in force since June 18, 2025), Belarus suspended the three articles from June 1, 2024, to December 31, 2026, and France suspended the same articles from June 1, 2024, to December 31, 2026, by virtue of reciprocity (Article 55 of the Constitution).

Belarus: Maximum Detentions and Key Rules

The doctrine specifies that articles 1 to 6, 9, 10 and 12 to 19 are not subject to suspension, and that point 2 of the protocol (shares and receivables recorded in the balance sheet of a permanent representation) remains in force.

What the suspension changes

The benefits of Articles 7 and 8 are no longer available, particularly regarding reduced withholding tax rates, and the income in question is taxed according to the domestic law of each State. The periods covered are, for interest, those between June 1, 2024, and December 31, 2026, and, for dividends, those for which the decision giving rise to their distribution occurred between June 1, 2024, and December 31, 2026. A pro rata temporis calculation may apply. Regarding tax credits, the taxes levied by Belarus on the dividends and interest in question do not give rise to any tax credit in France; they are deductible from the tax base under the standard rules. Income from property is taxable in France under the standard rules.

Typical case: dividends from a Belarusian company (fictitious profile)

Situation. A resident of France, a fictitious profile, holds shares in a Belarusian company and receives a dividend whose distribution is decided in 2025.

Issue. He wonders if the rate of 15 % in article 7 still applies.

Strategy. He identifies the date of the distribution decision, then reads the doctrine on suspension before any tax credit declaration.

Result. According to established practice, the reduced rate of 15% of the 13% tax year is inapplicable during the suspension period; Belarusian tax does not give rise to a tax credit in France and can be deducted from the tax base. No specific figures are provided here, as this depends on the domestic law of each state.

Articles that continue to apply

Article 1, paragraph 4, distinguishes between dual residence: permanent home, then center of vital interests, habitual residence, nationality, and agreement of the authorities. Article 9, paragraph 1, stipulates 183 days "during the calendar year," with two other conditions. Article 10, paragraph 2, reserves public service and social security pensions for the paying state; it does not mention private pensions, and Article 12 addresses other income.

What this sheet does not cover

The suspension is in effect until December 31, 2026; no source consulted specifies what happens after that date. Sanctions, banking restrictions, Belarusian taxes, wealth, and inheritance are not addressed.

What changes depending on your situation

• The date of the distribution decision or the interest period, in relation to the suspension.
• The nature of the income: dividend, interest, property income, salary, pension.
• Your residence as defined in the agreement and your days of presence during the calendar year.

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