The tax treaty between France and Burkina Faso no longer applies to income earned from November 8, 2023, onwards, nor to estates opened from that date. France suspended it on that day, and tax doctrine indicates that the termination takes effect on January 1, 2025. This document reflects the tax authorities' position, without presenting any applicable treaty ceiling.
A 1965 text, signed with Upper Volta
The convention was signed in Ouagadougou on August 11, 1965, with Upper Volta, which later became Burkina Faso, along with a protocol and an exchange of letters. An addendum is dated June 3, 1971. The administrative list classifies it among the texts concerning income tax, inheritance tax, and registration and stamp duties. The text contains a chapter on inheritance tax (articles 27 to 34).
From notification to denunciation: the dates
| Date | Event |
|---|---|
| August 7, 2023 | Burkina Faso notifies France of the cessation of application of the convention |
| November 8, 2023 | France suspends the convention, as a reciprocal measure. |
| December 31, 2024 | End of the suspension period |
| January 1, 2025 | Effective date of the denunciation |
The BOFiP indicates that the termination only takes effect from January 1, 2025.
This is no longer applied, and since when?
| Subject | Doctrine position (version of August 7, 2024) |
|---|---|
| Income tax | The convention no longer applies to income earned from November 8, 2023 onwards. |
| Successions | The convention ceases to apply to estates opened on or after November 8, 2023. |
| Dividends and interest | Taxable in France under the standard legal conditions |
| Royalties | The agreement provided for an exemption from withholding tax; they are now taxable in France under the standard rules. |
| Pensions and life annuities of French origin | They were exempt from tax in France under the treaty; in the absence of a treaty, they are taxable in France under the ordinary rules. |
This document therefore does not provide any conventional withholding rates.
Where to read the information
The list of agreements (BOI-ANNX-000306, version of April 29, 2026) retains the line for Burkina Faso with a note: suspension from November 8, 2023 to December 31, 2024, followed by denunciation from January 1, 2025. The page on the impots.gouv.fr website dedicated to the country does not mention either the suspension or the denunciation: only the texts of the agreement are published there.
The list is presented as that of the conventions in force on January 1, 2026, while maintaining Burkina Faso's position with this note. We are not making a definitive judgment on this apparent inconsistency: it can be verified with the source.
What this sheet does not cover
The status after January 1, 2025 could not be confirmed by a source subsequent to the doctrine of August 7, 2024. Business income, capital gains, Burkinabe-source income of a resident of France and the internal law of Burkina Faso are not addressed.
What changes depending on your situation
- The date on which income is earned or an estate is opened, relative to November 8, 2023.
- The nature of the income: dividend, interest, royalty, pension, annuity.
- Your tax residence, in France or Burkina Faso.
- The origin of the income: from French or Burkinabe sources.
A case file must be read with its dates, and no result is guaranteed in advance.
Frequently asked questions
Is the tax treaty between France and Burkina Faso still in force?
No, this does not apply to income acquired from November 8, 2023, onwards, nor to estates opened since that date. The doctrine of August 7, 2024, sets the deadline for notification as January 1, 2025.
Are dividends and interest still capped?
The doctrine indicates that they remain taxable in France under the ordinary legal conditions, without a treaty.
Who taxes the pensions of Burkina Faso residents?
According to the doctrine, residents of Burkina Faso who receive pensions and life annuities from French sources are taxable in France under the ordinary legal conditions.
What happens to the succession agreement with Burkina Faso?
According to legal doctrine, the convention ceases to apply to estates opened on or after November 8, 2023.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, assists executives and families whose assets or business activities have ties to France and Burkina Faso. To discuss your situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- French tax residence: the 3 criteria (art. 4 B)
- Leaving France: exit tax, tax residence, procedures
- Inheritance agreements: which countries with France
- Dividends paid to a non-resident: withholding tax of 12.8% %
- French interest and obligations of a non-resident
- Foreign bank account or contract: what needs to be declared?
Official sources
- BOFiP doctrine, France-Burkina Faso agreement (BOI-INT-CVB-BFA, version of August 7, 2024): https://bofip.impots.gouv.fr/doctrine/pgp/3112-PGP
- Consolidated text of the convention: https://www.impots.gouv.fr/10conventionsburkina-fasoversion-consolidee-burkina-fasopdf
- Country page, impots.gouv.fr: https://www.impots.gouv.fr/burkina-faso
- List of tax treaties (BOI-ANNX-000306): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
