Between France and Kosovo, the convention concluded with the former Yugoslavia on March 28, 1974, applies. An exchange of letters dated February 4 and 6, 2013, confirmed its continued application. It concerns only income tax. It caps withholding tax at 5% or 15% on dividends, and reserves interest and royalties for the beneficiary state.
A 1974 agreement, confirmed by an exchange of letters in 2013
The administrative list (BOI-ANNX-000306, dated April 29, 2016) cites, for Kosovo, the convention of March 28, 1974 (Official Journal of September 13, 1975) and the 2013 exchange of letters (Official Journal of April 26, 2013), and the "IR" category: neither wealth, nor inheritance, nor gift. It does not provide a BOFiP doctrine identifier for Kosovo. Decree No. 2013-349 of April 24, 2013, publishes the agreement signed in Paris on February 4, 2013, and in Pristina on February 6, 2013. In the French letter of February 4, 2013, France proposes "that the agreements listed in the annex to this letter continue to bind France and Kosovo"; the tax convention of March 28, 1974, is listed in point 12 of the annex. The agreement entered into force on 6 February 2013. Kosovo is not included in the list of conventions modified by the MLI (BOI-ANNX-000511, of 29 April 2026).
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 10 § 2 a) | 5 % of the gross amount if the beneficiary is a company that directly holds at least 25 % of the capital of the paying company |
| Dividends, other cases | 10 § 2 b) | 15 % of the gross amount |
| Interests | 11 § 1 | Taxable only in the beneficiary's state |
| Royalties | 12 § 1 | Taxable only in the beneficiary's state |
| Salaries, exception | 15 § 2 | Stay not exceeding 183 days during the fiscal year; employer not resident in the other State; expense not borne by a permanent establishment or fixed base |
| Pensions | 18 | Subject to Article 19, taxable only in the State of residence |
| Double taxation (France) | 23 A | Exemption of taxable income in Yugoslavia, except for that in paragraph b) (Articles 10, 16 and 17): tax credit equal to the Yugoslav tax, up to the limit of the French tax; paragraph c): rate corresponding to total income |
Who is a resident?
For a natural person resident in both States, Article 4 § 2 stipulates: a) the State of permanent home; b) the State of habitual residence; c) the State of which he or she is a national; d) failing that, the agreement of the competent authorities.
Dividends: a threshold of 25 %, direct
The threshold in Article 10 § 2 a) is 25,% of the capital held directly. The attached protocol does not cover dividends: it deals with ancillary activities of international shipping (Article 8) and the non-resident regime for French nationals (Article 24).
Interest and royalties: the beneficiary's state
Articles 11(1) and 12(1) stipulate that only the recipient's state is liable for taxation on interest and royalties arising from the other state. Paragraph 3 of each of these articles makes an exception for the case of a permanent establishment or fixed base in the source state.
France: tax exemption and tax credit
According to Article 23 A (a), income other than that mentioned in paragraph (b) is exempt from French tax when it is taxable in Yugoslavia under the convention. Paragraph (b) grants, for income covered by Articles 10, 16, and 17 (dividends, directors' fees, artists' and athletes' fees), a tax credit equal to the Yugoslav tax, up to the limit of the French tax. Paragraph (c) allows for the calculation of French tax at the rate applicable to total income.
What this page does not cover
Article 13 (capital gains), Article 22 (unspecified income items), the remainder of Article 26 concerning the exchange of information, and its application to the French wealth tax (IFI) are not detailed. Kosovo law is not addressed; its validity should be verified with a local professional.
Frequently asked questions
Which tax treaty applies between France and Kosovo?
The convention of March 28, 1974 with the former Yugoslavia. According to the exchange of letters of February 4 and 6, 2013, the agreements listed in the annex, including the 1974 tax convention (item 12), continue to bind France and Kosovo.
What is the withholding tax rate on dividends?
5 % of the gross amount for a company directly holding at least 25 % of the capital, 15 % in other cases (Article 10 § 2).
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 Kosovo. 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
- French pension of a non-resident: where is it taxed?
- Leaving France: exit tax, tax residence, procedures
- Foreign address: inform the tax authorities of your departure
Official sources
- Text of the convention of March 28, 1974: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/ex_yougoslavie/convention-avec-l-ex-yougoslavie_fd_1730.pdf
- State Succession Agreement with Kosovo (Decree No. 2013-349): https://www.impots.gouv.fr/sites/default/files/media/10_conventions/kosovo/kosovo-_accord_de_succession_detat.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
