The 1962 France-Lebanon tax treaty, point by point

The convention between France and Lebanon was signed in Paris on July 24, 1962, and entered into force on December 28, 1963. For dividends and interest, the tax authorities' guidance does not specify a withholding tax ceiling: they are taxable only in the beneficiary's country of residence. Royalties, on the other hand, are taxable in the country of origin. A second section deals with inheritances and, for securities, is based on the deceased's residence.

This page is based on the text of the agreement published by the tax authorities on impots.gouv.fr and on the official commentary (BOFiP), which includes the relevant articles. It indicates the article cited each time.

A 1962 document, a protocol, no listed amendments

The convention is accompanied by a protocol which forms an integral part thereof. It was approved by Law No. 63-813 of August 6, 1963, and published by Decree No. 64-5 of January 2, 1964. The commentary is in force in its version of September 12, 2012, for the whole, and of July 28, 2014, for the "income" section.

Article 42 sets out the application dates. Withholding tax on investment income applies to payments made on or after March 29, 1964. Other income taxes apply to income earned in 1963 or for fiscal years ending in 1963. Inheritance tax applies to individuals who died on or after November 28, 1963.

The list of tax treaties issued by the administration (April 29, 2026) includes the entry "IR – S" for Lebanon: income tax, inheritance tax. No amendments are listed.

What the convention covers

The "income" section covers personal income tax and corporate income tax in metropolitan France and its overseas departments. The "inheritance" section covers inheritance tax in each state. It excludes taxes on gifts made during one's lifetime, except as provided for in Articles 35 and 36.

Article 2: Where do you reside?

A person is a resident of a State if they are subject to tax in that State by reason of their domicile, residence, place of management, or any other similar criterion. If an individual is a resident of both States, the relevant criterion is their center of vital interests, that is, the place where their personal and professional ties are closest. Failing that, it is the State where they reside for the longest period. For a legal entity, the criterion is its place of effective management.

French tax residence itself is determined by article 4 B of the CGI, discussed on our page regarding its three criteria.

Dividends and interest: taxed in the state of residence

This is the distinctive feature of this convention. Dividends and interest (Articles 15 § 1 and 16) are taxable only in the state of residence of the beneficiary.

A procedural requirement applies to residents of France. If prior justification is lacking and the source country withholds tax upon payment, the commentary indicates that the recipient cannot subsequently claim a refund. The commentary does not specify a rate; there is no ceiling to cite for these two types of income.

Royalties: taxable in the state of origin

Royalties arising in one State and paid to a resident of another are taxable in the first State (Article 17, paragraph 1). According to Article 17, paragraph 2, subject to Article 26, paragraph 3, the State of which the recipient is a resident retains the right to tax them according to its own laws, unless that recipient has, in the State from which the royalties arise, a permanent establishment or a fixed place for the exercise of a "liberal profession or other independent activity" to which the right is effectively connected; in that case, Article 10 or Article 22, as the case may be, applies. Double taxation is avoided by the methods of Article 26. The commentary does not provide any rates. Sums paid for the rental of motion pictures and equipment are treated as royalties (Article 17, paragraph 4). For these products only, the commentary specifies that withholding tax must continue to be carried out under the conditions provided for by domestic law.

Salaries, pensions, public remuneration

The conditions of the temporary mission and the consequence of exceeding the threshold of one hundred and eighty-three days are shown in the table above.

Real estate, profits, other income

The taxation of property income and agricultural or forestry profits is reserved to the State where the property is situated (Article 9). Income not covered by an article is taxable only in the State from which it originates (Article 25).

The BOFiP commentary does not address capital gains. Article 13, paragraph 1, reserves income from the sale of a stake in a capital company to the State of which the seller is a resident; paragraph 2 excludes this rule when the stake forms part of the assets of a permanent establishment that the seller owns in the other State, in which case Article 10 applies. This page says nothing about other types of capital gains.

Eliminating double taxation: Article 26

For income exclusively taxable in the other state, Article 26, paragraph 1, excludes it from the French tax base. Paragraph 2 allows France to calculate tax on other income at the rate applicable to all taxable income under its legislation. For royalties, directors' fees, non-commercial professions, and artists' fees, paragraph 3 avoids double taxation by crediting Lebanese tax against French tax, without exceeding the corresponding French tax liability.

Inheritance: the deceased's residence

The commentary in the "inheritance" section distinguishes several categories of assets:

• Buildings are subject to inheritance tax only in the state where they are located; ;
• Tangible personal property is subject to inheritance tax in the state where it is located on the date of death, boats and aircraft in the state of registration; ;
• Securities, receivables and intellectual property are subject to tax only in the State of which the deceased was a resident at the time of his death (Article 32); ;
• When the deceased was a resident of Lebanon, these assets cease to be subject to inheritance tax in France, unless they are invested in a business or attached to a liberal profession.

Business assets follow the permanent establishment (Article 29), the commentary excluding from this article participations in capital companies and professional facilities in the State where they are located (Article 30). The commentary also addresses the allocation of debts and the average tax rate. It does not contain a general rule on the taxation in France of a resident of Lebanon; this page does not go beyond the above.

Exchange of information

Articles 37 to 39 provide for administrative assistance between the two states, either automatically or upon request in specific cases. Lebanon is listed in the table in the annex to the 2027 draft budget law concerning the exchange of information, and is not among the 11 states on the French list of non-cooperative states and territories, as of the date of the annex.

Lebanese royalties and tax credit: a numerical example (fictitious profile)

Situation. A hypothetical French resident receives €10,000 in royalties from Lebanese sources. Lebanon levies €1,500 in tax in this scenario. The corresponding French tax on these royalties is €1,100.

Issue. He wants to know what portion of Lebanese tax is deducted from French tax.

Strategy. It applies article 26 § 3: the credit is the Lebanese tax, capped at the corresponding French tax.

Result. The tax credit is €1,100 (the smaller of the two amounts). This reduces the French tax on these royalties to €0. The remaining €400 of Lebanese tax is not deductible. The amounts are hypothetical: the commentary does not provide any tax rates, and the actual Lebanese tax depends on Lebanese law.

What changes depending on your situation

• Your residence as defined in Article 2, which is not the domicile as defined in Article 4 B of the CGI.
• The nature of the income: dividend, interest, royalty, salary, pension.
• The nature and location of your assets, and your residence at the time of death, for inheritance purposes.
• The formalities to be completed before payment in order to obtain the exemption at source.

The rule depends on your situation. No results are guaranteed.