For Kyrgyzstan, the administrative list cites the convention concluded with the former USSR on October 4, 1985, which legal doctrine indicates continues to have effect with respect to Kyrgyzstan. It caps the withholding tax at 15 % on dividends and at 10 % on most interest. This page reads this text and explains what it does not address.
A convention signed with the USSR, applied to Kyrgyzstan
The administrative list (BOI-ANNX-000306, dated April 29, 2026) cites, for Kyrgyzstan, the convention of October 4, 1985 (Official Journal of May 28, 1987) and an exchange of letters dated March 14, 1967. It classifies it as "IR": neither wealth, nor inheritance, nor gift tax. The BOFiP page (BOI-INT-CVB-KGZ, in force since September 12, 2012) indicates that the convention entered into force on March 28, 1987, and "continues to have effect with respect to Kyrgyzstan." On the French side, it concerns income tax and corporation tax. Kyrgyzstan is not included in the list of conventions amended by the MLI (BOI-ANNX-000511, dated April 29, 2026).
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 7 § 1 | Taxable in the state of the paying company; the tax cannot exceed 15% of the gross amount. |
| Interests | 8 | Interest other than that on bank and commercial loans is taxable at source, up to a limit of 10% of the gross amount. |
| Copyright, licenses | 6 | Not taxable in the source state |
| Salaries, exception | 9 § 1 | Stay not exceeding a total of 183 days during the calendar year; employer not resident in the other State; expense not borne by a permanent representation |
| Movable property | 11 § 2 | Proceeds from alienation not taxable in the other State (excluding assets of a permanent representation), subject to point 3 of the protocol (substantial shareholdings, not detailed here) |
| Unlisted income | 12 | Not taxable in the source state |
| Double taxation (France) | 15 § 4 | Exemption of income not covered by paragraph b; tax credit for dividends and interest |
Who is a resident?
Article 1, paragraph 4, governs the residence of natural persons: a) a person is considered a resident of the State in which they have a permanent home (if they have one in both States, the one in which their center of vital interests is located); b) if the State in which their center of vital interests is located cannot be determined, they are a resident of the State in which they habitually reside; c) if they habitually reside in both States, they are a resident of the State of which they are a national; d) if they are a national of both States, the competent authorities shall decide by mutual agreement. Article 4 of the text does not deal with residence: it concerns permanent representations.
Exchange of information: what the convention does not cover
According to the BOFiP website, this convention "does not contain a clause providing for the exchange of information relating to the application of domestic legislation." Article 16 provides for exchanges, within the limits of each State's national legislation, for the application of the convention.
The 183-day rule: calendar year, permanent representation
Article 9 § 1 sets out three cumulative conditions: a stay of no more than 183 days in total during the calendar year, an employer who is not resident in the other State, and an expense not borne by a permanent representation that the employer has in the other State.
What this page does not cover
Substantial shareholdings (protocol), details of the bank interest regime, public pensions, and application to the French wealth tax (IFI) are not covered. Kyrgyz law is not addressed; its validity should be verified with a local professional.
Frequently asked questions
Which tax treaty applies between France and Kyrgyzstan?
The one of October 4, 1985 concluded with the former USSR, which continues to produce its effects with regard to Kyrgyzstan according to the BOFiP page.
What is the withholding tax rate on dividends?
The ceiling is 15 % of the gross amount (article 7 § 1).
Does the treaty cover estates?
No, according to the administrative list of April 29, 2026, which classifies it as "IR" alone.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, assists executives and families whose assets or business activities have ties to France and Kyrgyzstan. To discuss your 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
- Tax treaties: countries linked to France
- Dividends paid to a non-resident: withholding tax of 12.8% %
- Double taxation: tax credit and effective tax rate
- Capital gains on non-resident securities: when France taxes
- Leaving France: exit tax, tax residence, procedures
- Foreign address: inform the tax authorities of your departure
Official sources
- BOFiP doctrine, France-USSR convention applicable to Kyrgyzstan (BOI-INT-CVB-KGZ): https://bofip.impots.gouv.fr/bofip/1783-PGP.html
- Text of the convention of October 4, 1985: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/ex_urss/fichedescriptive_62371.pdf
- 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