The France-Georgia tax treaty: dividends subject to investment thresholds, interest and royalties in the beneficiary's country

Under the France-Georgia tax treaty, interest and royalties are taxable only in the country of the beneficial owner. Dividends are capped at 5 % or 10 %, or are not taxable in the payer's country for a shareholding of at least 50 %.

Signed in 2007, implemented since 2011, amended by the MLI in 2020

The convention was signed in Paris on March 7, 2007, with a protocol forming an integral part thereof. It was approved by Law No. 2010-202 of March 2, 2010, published by Decree No. 2010-582 of June 1, 2010, and entered into force on June 1, 2010. Withholding taxes apply to taxable amounts from January 1, 2011, like other taxes, for fiscal years beginning on or after that date (Article 30).

List BOI-ANNX-000306 (April 29, 2026) classifies it with the headings "IR – IF". The multilateral convention (MLI) modifies it: according to list BOI-ANNX-000511, the effects in France begin on January 1, 2020, for withholding taxes as well as for other taxes.

Maximum deductions and key rules

Dividends: three cases, two investment thresholds

Article 10, paragraph 2, distinguishes three cases. First case: the beneficial owner is a company resident in the other State that holds, directly or indirectly, at least 50% of the capital of the paying company, and that has invested at least €3 million by the date of payment. The dividends are then not taxable in the paying State.

Second case: the company holds at least 10 % of the capital and has invested more than 100,000 euros: the withholding tax is capped at 5 %. In other cases, the cap is 10 %.

Interest and royalties: the beneficial owner's state

Articles 11 and 12 make interest and royalties taxable only in the country of the beneficial owner, subject to the clause on entitlement to benefits. The actual absence of withholding tax depends on domestic law and formalities, which this page does not address.

Right to benefits: the clause stemming from the MLI

The consolidated text denies the benefit of the convention for an item of income if it is reasonable to conclude that obtaining it was one of the principal objects of an arrangement, unless it is established that granting it would be consistent with the object and purpose of the convention.

Salaries and residence

Article 15, paragraph 2(a), excludes taxation in the State of employment if the stay does not exceed a total of 183 days "during any twelve-month period commencing or ending in the relevant fiscal year." The employer must not be a resident of the State of employment, and the remuneration must not be borne by a permanent establishment or fixed base that the employer has.

In the case of dual residence, Article 4 § 2 applies in this order: permanent home and center of vital interests, habitual residence, nationality, then agreement between authorities.

Eliminating double taxation (Article 24)

France applies a tax credit. For other income, it is equal to the corresponding French tax if the resident is subject to Georgian tax; for dividends (Article 10), and in particular the gains under Article 13 § 1, it is equal to the tax paid in Georgia. In both cases, it is capped at the corresponding French tax. Georgia grants a deduction of the French tax paid, also capped.

What this page does not cover

It does not address the protocol, Article 23 on wealth, the amicable settlement procedure, the exchange of information, the IFI (French wealth tax), or Georgian domestic law. The administrative list makes no mention of inheritances or gifts.

What changes depending on your situation

• The level of ownership of the beneficiary company and the amount invested at the payment date.
• The reasons for the arrangement (clause on the right to benefits).
• Your residence as defined in Article 4.
• Your travel schedule.