The 1999 France-Guinea tax treaty: withholding taxes and French tax credits

The France-Guinea convention of February 15, 1999, caps withholding tax at 15% for dividends and 10% for interest and royalties. Article 24 contains a time-limited, five-point increase clause, which is used to calculate the French tax credit and not the withholding tax itself. Only the articles included in the text are reproduced; the rest are indicated as not addressed.

A 1999 convention, in force since October 1, 2004

The convention was signed in Conakry on February 15, 1999. It was approved by Law No. 2003-375 of April 24, 2003, and published by Decree No. 2004-1008 of September 17, 2004. It entered into force on October 1, 2004. Withholding taxes apply from that date. Other income taxes apply to fiscal years beginning on or after January 1, 2005 (Article 30).

The administrative list BOI-ANNX-000306 (April 29, 2026) includes the entries "IR – IF – S – D". Guinea is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, April 29, 2026).

Maximum deductions and key rules

A five-point increase: a tax credit calculation, for ten years

Article 24 § 1 e) does not raise the ceilings of Articles 10 § 2 and 11 § 2. For the calculation of the French tax credit, the "amount of tax paid in Guinea" on dividends and interest is established at the rates of these paragraphs "increased by five points", within the limit of the Guinean ordinary tax.

This rule applies "for ten years from the date of entry into force" of the convention, i.e., ten years from October 1, 2004, unless extended by mutual agreement of the competent authorities. No extension appears in the sources consulted: its status should be verified with the official source.

Inheritance taxes and wealth

Article 2 lists "transfer taxes on gifts and inheritances" among the taxes covered, both for France and for Guinea. The administrative list includes the abbreviations IF, S, and D (wealth, inheritances, gifts). The text comprises Article 22, entitled "Wealth," and Article 23, entitled "Gifts and Bequests," which are not detailed on this page.

Residence and salaries

Article 4 § 2 distinguishes between dual residence: permanent home, center of vital interests, habitual residence, nationality, amicable agreement of the competent authorities.

For wages, Article 15 § 2 a) stipulates a stay not exceeding a total of 183 days "during any period of twelve consecutive months beginning or ending in the tax year in question." Two other conditions relate to the payer and the responsibility for the remuneration.

Eliminate double taxation

For France, Article 24 § 1 provides for a tax credit, up to the amount of the corresponding French tax. For Guinea, Article 24 § 2 provides for a credit of the French tax paid, which cannot exceed the amount of Guinean tax corresponding to this income.

What this page does not cover

It does not deal with the content of articles 22 and 23, the withholding tax of article 10 § 3, the exchange of information, the IFI or Guinean domestic law.

What changes depending on your situation

• The date of your income, with regard to the ten-year clause of Article 24 § 1 e).
• The nature of the income and your residence.
• Your travel schedule.