The 1993 France-Ghana tax treaty: different ceilings depending on the source country

Under the France-Ghana tax treaty, the withholding tax ceiling depends on the country where the income originates. Interest from French sources is capped at 10 %, while interest from Ghanaian sources is capped at 12.5 %. Dividends are capped at 5 % or 7.5 % for certain companies, and 15 % otherwise.

A 1993 convention, in force since April 1, 1997

The convention was signed in Accra on April 5, 1993. It was approved by Law No. 94-925 of October 26, 1994 and published by Decree No. 97-474 of May 6, 1997. It entered into force on April 1, 1997. Article 30 stipulates that withholding taxes apply "to amounts taxable from January 1, 1998.".

The administrative list BOI-ANNX-000306 (April 29, 2026) classifies it with the sole designation "IR". Ghana is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, April 29, 2026).

Maximum deductions and key rules

The dividend ceiling is based on the residence of the paying company (5 % if it is resident in France, 7.5 % if it is resident in Ghana), while the interest and royalty ceiling is based on the residence of the beneficial owner.

A separate article: executive service compensation

Article 13 deals separately with remuneration for management, technical, or consulting services paid to a person other than an employee of the debtor. The source state may tax such remuneration up to a limit of 10% of the gross amount, if the recipient is the beneficial owner.

Numbering to know

Capital gains are in Article 14, wages in Article 16 and pensions in Article 19.

• Earnings Gains on real estate are taxable in the State where the property is located (Article 14 § 1). Gains on other property are taxable only in the State of which the transferor is resident (Article 14 § 4).
• Wages The exception in Article 16(2)(a) concerns a stay not exceeding a total of 183 days "during any period of twelve consecutive months". Two other conditions relate to the payer and the permanent establishment or fixed base.
• Pensions : subject to Article 20 § 2, those which are paid in respect of previous employment are taxable only in the State of residence of the beneficiary, if that resident is subject to tax there (Article 19 § 1).
• Buildings : income from real estate is taxable in the State where it is located (Article 6 § 1).

Residence and double taxation

The determination of dual residence (Article 4 § 2) takes into account the permanent home, the center of vital interests, the habitual residence and nationality, before the agreement between authorities.

For France, Article 24 § 1 grants a tax credit "offset against French tax," up to a limit linked to the corresponding French tax. For Ghana, Article 24 § 2 entitles taxpayers to a credit against French tax on income from French sources, limited to the corresponding portion of Ghanaian tax.

What this page does not cover

It does not address Ghanaian domestic law, Article 10 § 6 (permanent establishment), Article 11 § 3 (interest taxable only in the State of residence in certain cases), Article 13 § 4 (remuneration attributable to a permanent establishment), the details of Article 14 § 1 b), non-discrimination, the exchange of information, or the IFI (Wealth Tax). The rates in the table do not apply to these cases. The administrative list does not mention wealth or inheritances.

What changes depending on your situation

• The state where the income originates (rates differ in both directions) and, for dividends, the shareholding of the beneficiary company.
• The classification of the payment: royalty or management services.
• Your stays over the twelve-month period of the text.