The France-Cyprus tax treaty, point by point

The tax treaty between France and Cyprus was signed in Nicosia on December 18, 1981. It has been in force since April 1, 1983. It specifies, income by income, which state may tax. For dividends, the tax of the source state is capped at 15% of the gross amount in general; for interest, the cap is 10%; for private pensions, taxation falls to the state of residence. No amendments are mentioned, and Cyprus is included in the list of treaties modified by the Multilateral Convention (MLI).

A text from 1981, in force since 1983

The convention was signed in Nicosia on December 18, 1981, with a protocol having the same force as the convention. It was approved by Law No. 82-1093 of December 23, 1982, and published by Decree No. 83-250 of March 18, 1983, in the Official Gazette of March 30, 1983. It entered into force on April 1, 1983.

Article 31 sets out the application dates.

The administration's commentary bears the reference BOI-INT-CVB-CYP. It has been in effect since September 12, 2012, with no stated end date. The 2012 version is outdated: read it in conjunction with the text of the agreement and the MLI list.

Amendments and Multilateral Convention (MLI)

Neither the text of the agreement, nor the BOFiP commentary, nor the administrative list of agreements mentions an amendment.

Cyprus, however, is included in the list of conventions amended by the multilateral convention (BOI-ANNX-000511, dated April 29, 2026). The effective date in France is set for January 1, 2021, for taxes withheld at source and November 1, 2020, for other taxes. The consolidated text published by the tax authorities does not include any notes from the Multilateral Tax Institution (MLI) on Articles 4, 10, 11, 12, 16, and 19 cited here. It adds a clause entitled "Right to the Benefits of the Convention" and amends the preamble and Articles 9, 27, and 31.

Income-based rules

Dividends

For dividends, Article 10 caps the withholding tax at 15 % of the gross amount in general, and at 10 % when the beneficiary is a company, other than a partnership, that directly holds at least 10 % of the capital. The other conditions for this second cap are detailed in the article before any decision is made.

Interest and royalties

Regarding interest, Article 11 sets a cap of 10% of the gross amount. This cap establishes a maximum that the source state can levy. The actual interest rate applied depends on the domestic law of that state, which is not covered on this page.

The article specifies that certain interest is taxable only in the state of residence: state interest, interest from equipment sales on credit, and interest from bank loans. The conditions for these categories are detailed in the text.

For royalties, Article 12 generally refers to the State of residence. Film royalties are treated separately: the tax cannot exceed 5% of the gross amount.

Wages and the 183-day rule

The general rule is that the state of residence is the determining factor: the wages of a resident of one state are taxable in that state, unless the employment is carried out in the other state.

The exception based on duration applies if the stay in the other state does not exceed 183 days in total. Other conditions apply, which are not detailed on this page. The count of days should not be considered in isolation; the entire text of the article must be examined.

Private guesthouses

Private pensions paid in respect of previous employment are taxable only in the recipient's country of residence. Social security and public pensions follow different rules, which are not detailed here.

If both France and Cyprus consider you a resident

When two states each consider you a resident, the tax treaty makes the final decision. Its definition of resident takes precedence over domestic tax domicile. Article 4, paragraph 2 of the treaty distinguishes between these factors in this order: permanent home, center of vital interests, habitual residence, nationality, and finally, an amicable agreement between the competent authorities.

Successions

The administrative list of conventions contains only one entry for Cyprus and no entry for inheritance. This absence from the list is not sufficient to determine the rules governing your inheritance: verify the status of each asset under the domestic law of each country before making any decisions.

What this page does not cover

The taxes covered by the convention, capital gains, the method of eliminating double taxation (tax credit or exemption), and the protocol are detailed in the text. Cypriot taxation itself, particularly the regime for non-residents, is not addressed here.

Numerical example (fictitious profile)

Situation. A French retiree, fictitious profile, resident of Cyprus, receives from a French company a gross dividend of €40,000 and gross interest of €100,000.

Issue. He wonders what the convention allows as a levy in the source state. It caps the tax at 15 % for dividends in the general case, and at 10 % for interest.

Strategy. He identifies the nature of each income, rereads the corresponding article in its entirety, and checks whether one of the exceptions in Article 11 (State, equipment credit sales, bank loans) applies to it.

Result. On €40,000 of dividends, the 15% withholding tax cap represents a maximum of €6,000. On €100,000 of interest, the 10% withholding tax cap represents a maximum of €10,000. If the interest falls into one of the categories taxable only in the country of residence, the country of origin cannot tax it. The actual withholding tax rate depends on the domestic law of each country.

What changes depending on your situation

• Your residence as defined in the convention, which depends in particular on your permanent home.
• The nature of the income: dividend, interest, royalty, salary, pension.
• The location where the job is performed and the number of days spent in each state.
• The payment date and the effect of the MLI on your situation.

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