The convention between France and Latvia was signed in Paris on April 14, 1997, and entered into force on May 1, 2001. It covers taxes on income and capital. It caps withholding tax at 5 or 15 on dividends and at 10 on interest, subject to the exemptions in Article 11, paragraph 3; royalties are taxable only in the recipient's country.
A 1997 text, the MLI, then the most-favored-nation clause
The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it as "IR – IF" and makes no mention of inheritance or gifts. It was approved by Law No. 2001-87 of January 30, 2001, and published by Decree No. 2001-457 of May 22, 2001. According to the BOI-ANNX-000511 list, the MLI (Minimum Tax Incentive) takes effect on January 1, 2021, for taxes withheld at source and on August 1, 2020, for other taxes; the doctrine specifies that the MLI adds a general anti-abuse rule. The BOFiP update of October 16, 2024, implements the most-favored-nation clause, effective July 5, 2017, following the Latvia-Japan Convention. Article 2 § 3 mentions the wealth solidarity tax for France; the IFI is not named there.
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 10 § 2 a) | 5 % of the gross amount if the beneficial owner is a company that holds at least 10 % of the capital of the paying company (directly if the paying company is Latvian; directly or indirectly if it is French) |
| Dividends, other cases | 10 § 2 b) | 15 % of the gross amount |
| Interests | 11 § 2 | The tax may not exceed 10 % of the gross amount, subject to § 3 |
| Interest on a loan from a credit institution | 11 § 3 d) | Taxable only in the beneficiary's state of residence (note 3, protocol § 8) |
| Royalties | 12 § 1 | Taxable only in the State of the beneficial owner; paragraph 2 is blank (note 4, protocol paragraph 9) |
| Capital gains (other assets) | 13 § 4 | Taxable only in the state where the transferor is resident |
| Salaries, exception | 15 § 2 a) | Stay not exceeding a total of 183 days during any period of twelve consecutive months |
| Public pensions | 19 § 2 | a) taxable only in the State that pays them; b) referral to the other State in the case provided for in the text |
| Double taxation | 23 § 1 a) and § 2 a) | Tax credit deductible from French tax "under the conditions and within the limits provided"; on the Latvian side, a credit equal to the tax paid in France, up to the limit of the corresponding fraction of Latvian tax |
Who is a resident?
Article 4 § 2 first considers the permanent home. If the center of vital interests cannot be determined, it examines the habitual residence in both States, then the nationality of both States.
Interest and royalties: what the notes in the text change
The consolidated text bears the mark of the most-favored-nation clause. The 10% rate in Article 11, paragraph 2, is subject to the cases in paragraph 3: subparagraphs (a) to (c) provide for other exemptions, which the text lists. In Article 11, paragraph 3 (d), interest paid on a loan of any kind granted by a credit institution is taxable only in the State of residence of the beneficiary (note 3, Protocol paragraph 8). In Article 12, paragraph 2 is blank in this version, and note 4 refers to paragraph 9 of the Protocol. The first paragraph reserves royalties to the State of the beneficial owner.
Capital gains and salaries
Article 13, paragraph 1(a), makes gains on immovable property taxable in the State where the property is situated; paragraph 4 reserves other gains for the State of residence of the transferor. For wages, the 183-day period of Article 15, paragraph 2(a), is a period of twelve consecutive months.
What this page does not cover
The content of the article on wealth, Article 24 (non-discrimination), the other steps in determining residency, and the application to the IFI (Wealth Tax) are not detailed. Latvian law is not addressed.
Frequently asked questions
What is the withholding rate on interest between France and Latvia?
10 % of the gross amount, subject to § 3 (Article 11 § 2). Interest on a loan granted by a credit institution is taxable only in the State of residence of the beneficiary (Article 11 § 3 d).
What is the rate on royalties?
Article 12 § 1 makes them taxable only in the State of the beneficial owner.
Does the treaty cover estates?
No, according to the administrative list of April 29, 2026, which classifies it as "IR - IF": wealth tax is targeted, no inheritance or donation is mentioned.
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 connect France and Latvia. 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
Official sources
- BOFiP doctrine, France-Latvia convention (BOI-INT-CVB-LVA): https://bofip.impots.gouv.fr/bofip/3245-PGP.html
- Consolidated text of the convention (MLI and most-favored-nation clause): https://www.impots.gouv.fr/sites/default/files/media/10_conventions/lettonie/lettonie—version-consolidee-cml–npf.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
