The France-Iran convention, signed in Tehran on November 7, 1973, is on the list of conventions in force as of January 1, 2026. It concerns income tax. It caps withholding tax at 15 or 20 for dividends, 15 for interest, and 10 for royalties. This page reproduces the text as read, without commentary on current events.
A text from 1973, in force since April 10, 1975
The convention was approved by Law No. 74-1010 of December 2, 1974, and published by Decree No. 75-302 of April 17, 1975. It entered into force on April 10, 1975. Article 29 stipulates that withholding taxes apply to sums paid from that date. For other taxes, it uses the year 1976 in France and the fiscal year beginning March 21, 1976, in Iran.
List BOI-ANNX-000306 (April 29, 2026) classifies it with the sole designation "IR", without a note. Iran is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, April 29, 2026).
Maximum deductions and key rules
| Subject | Article | Rule read in the text |
|---|---|---|
| Dividends, company directly holding at least 25 % | 10 § 2 a) | State tax at source limited to 15 % of the gross amount |
| Dividends, other cases | 10 § 2 b) | Limited to 20 % |
| Interests | 11 § 2 | Limited to 15 % of the amount |
| Royalties | 12 | Taxable in the recipient's state; the source state may tax them up to 10% of the gross amount. |
| Buildings, income and profits | 6 § 1; 13 § 1 | Taxable in the state where the property is located |
| Other earnings | 13 § 3 | Only in the state where the transferor is resident |
| Salaries, exception | 15 § 2 a) | a maximum of 183 days during the fiscal year in question |
| Pensions | 18 | Only in the State of residence, subject to Article 19 § 1 |
Dividends: 15 % or 20 % depending on the direct holding of 25 %
The 15 % limit applies if the beneficiary is a company, excluding partnerships, that directly holds at least 25 % of the capital of the paying company. In all other cases, the limit is 20 %.
The 183-day threshold: the fiscal year
For wages, Article 15 § 2 a) refers to a stay not exceeding a total of 183 days "during the relevant tax year." The reference is the tax year, not a period of twelve consecutive months. The text adds two conditions, concerning the employer and the payment of remuneration by a permanent establishment or fixed base.
Public pensions and salaries
Article 18 reserves pensions paid for previous employment to the State of residence, subject to Article 19, paragraph 1. The latter makes taxable in the State paying them remuneration and pensions paid by a State, a local authority, or a public institution for functions of a public nature. Article 19, paragraph 2, refers to Articles 15, 16, and 18 for services rendered in a commercial or industrial activity.
In France: exemption of other taxable income in Iran
Article 23, paragraph 2(a), exempts from French tax income other than that referred to in subparagraph (b) when it is taxable in Iran under the convention. Subparagraph (b) deals in particular with dividends, interest, and royalties, with a tax credit.
Residence
Article 4, paragraph 1, defines a resident as any person liable to tax in a State under its legislation. Paragraph 2 distinguishes between dual residence: permanent home, center of vital interests, habitual residence, nationality, and a decision by the competent authorities by mutual agreement.
What this page does not cover
It does not address Iranian domestic law, the exclusion of certain income provided for in Article 1, the exchange of information, the mutual agreement procedure, the IFI, or the practical application of the convention.
What changes depending on your situation
- The nature of the income and its state of source.
- The level of direct ownership of the company that pays the dividends.
- Your residence as defined in Article 4.
- The fiscal year in which your stays fall.
The text should be read in conjunction with the documents in your file; no result is guaranteed in advance.
Frequently asked questions
What is the maximum withholding tax on dividends between France and Iran?
15 % for a company directly holding at least 25 % of the capital, 20 % in all other cases (Article 10 § 2).
Does the France-Iran convention cover wealth tax or inheritance tax?
Article 2 refers to income taxes, and the administrative list only bears the mention "IR".
Is the 183-day rule calculated over a rolling twelve-month period?
No, the text refers to "the tax year in question" (Article 15 § 2 a).
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, assists families and business leaders whose situations involve both France and Iran. To discuss your specific situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- 183-day rule: employees on assignment and agreements
- French tax residence: the 3 criteria (art. 4 B)
- Double taxation: tax credit and effective tax rate
- Dividends paid to a non-resident: withholding tax of 12.8% %
- French pension of a non-resident: where is it taxed?
- Foreign bank account or contract: what needs to be declared?
Official sources
- List of tax treaties (BOI-ANNX-000306): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
- List of agreements modified by the MLI (BOI-ANNX-000511): https://bofip.impots.gouv.fr/bofip/14854-PGP.html/identifiant=BOI-ANNX-000511-20260429
- BOFiP doctrine, France-Iran convention (BOI-INT-CVB-IRN): https://bofip.impots.gouv.fr/doctrine/BOI-INT-CVB-IRN
- Text of the agreement: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/iran/iran_convention-avec-l-iran_fd_1881.pdf