The France-Egypt tax treaty: dividends without tax, interest and royalties at 15 %

The France-Egypt treaty does not specify a tax rate on dividends; they are taxable only in the recipient's country. Interest and royalties are capped at 15%. This document outlines the articles we have read and explains what it does not cover.

Three dates: 1980, 1999, 2021

The convention was signed in Paris on June 19, 1980, with a protocol, and entered into force on October 1, 1982. The amendment of May 1, 1999, entered into force on June 1, 2004, and applies to amounts taxable from January 1, 2005. The administrative list classifies the convention among those which concern income and capital.

The convention is also amended by the MLI. According to the BOI-ANNX-000511 list, the effective date is set for January 1, 2021, for withholding taxes and July 1, 2021, for other taxes. The consolidated text contains a clause on the right to benefits: a benefit is denied if one of the main objectives of an arrangement was to obtain it.

The ceilings and key rules

For securities of companies with real estate assets, the reference period is 365 days.

Pensions and wealth

Article 18 states that a private pension follows the beneficiary's residence and a social security pension follows the state whose legislation pays it.

Article 23 covers wealth: real estate is taxable in the state where it is located, assets of a permanent establishment or fixed base in the state concerned, and other assets in each state according to its own legislation. The text refers to the wealth tax; the IFI (French real estate wealth tax) is not mentioned, and this document does not address it.

Avoiding double taxation

Article 24 provides for a tax credit for French taxpayers on income taxable in Egypt, limited to the corresponding French tax, and a credit for any Egyptian wealth tax. Egypt exempts income taxable in France in the specified cases and grants a credit for certain French-source income.

For an individual resident in both States, Article 4 applies, in order, the following criteria: permanent home, center of vital interests, habitual residence, nationality, and then the agreement of the authorities. Article 27 governs the exchange of information.

What this sheet does not cover

Article II of the protocol on remuneration for studies and consultants is not included: the sources consulted differ. Egyptian domestic taxation, the mutual agreement procedure, and its application to the wealth tax are not addressed.

What changes depending on your situation

• Your residence as defined in Article 4.
• The nature of the income: dividend, interest, royalty, capital gain, pension.
• The origin of the pension: previous employment or social security.
• The number of days spent in each state during the fiscal year.

The above rules are verified on the documents in your file, and no result is guaranteed in advance.