The France-Lithuania tax treaty: dividends at 5% or 15%, interest at 10%.

The France-Lithuania tax treaty sets three withholding tax ceilings: 5% or 15% on dividends depending on the shareholding, and 10% on interest. Royalties are taxable only in the country of the beneficial owner.

Signed in 1997, amended by the MLI since 2019

The convention was signed in Paris on July 7, 1997, along with a protocol. It entered into force on May 1, 2001 (BOFiP, BOI-INT-CVB-LTU). The Multilateral Convention (MLI) amends it: according to the list in BOI-ANNX-000511, its effects began on January 1, 2019, for taxes withheld at source and on July 1, 2019, for other taxes. The consolidated text adds a clause: an advantage is not granted if obtaining it was one of the principal objectives of an arrangement or transaction, unless its granting would be consistent with the object and purpose of the relevant provisions.

Lithuania: Maximum withholdings and key rules

Royalties: the Japanese clause and the 2023 agreement

The protocol contains a most-favored-nation clause, implemented following the Lithuania-Japan Convention of July 13, 2017. According to the French Official Tax Bulletin (BOFiP) (points 8 and 9 of the protocol), it has been applicable since August 31, 2018, and concerns bank loan interest (Article 11 § 3 d)), royalties, and their definition. The BOFiP adds that, by mutual agreement of January 23 and 28, 2023, royalties paid to a resident of the other State who is not the beneficial owner are also taxable in the State of source.

Residence, employees and wealth

Article 4 defines a resident as any person liable for tax by virtue of their domicile, residence, place of management, or any similar criterion. For an individual resident in both States: permanent home, vital interests, habitual residence, nationality, and then approval by the authorities.

Article 15 sets the threshold at 183 days during any twelve-month period beginning or ending in the relevant fiscal year. The employer must not be a resident of the other State, and the remuneration must not be borne by a permanent establishment or fixed base.

The text refers to the wealth tax in France: its application to the real estate wealth tax is not established by the sources consulted.

Dividends of €60,000: a numerical example (fictitious profile)

Situation. A resident of Lithuania, a natural person, fictitious profile, receives €60,000 gross in dividends from a French company.

Issue. He wants to know the ceiling gap.

Strategy. It applies Article 10 § 2 and verifies its status as beneficial owner.

Result. The ceiling is €9,000 (15 %s of €60,000) in his case. For a company holding, directly or indirectly, at least 10 %s of the French company's capital, it would be €3,000 (5 %s), i.e., €6,000 less. This calculation gives the maximum allowed by the treaty, not the tax actually due.

Elimination of double taxation in France

Article 23 stipulates that, for income taxable in Lithuania that is not exempt from corporate income tax, Lithuanian tax is not deductible. A tax credit is granted, capped at the corresponding French tax.

What the page doesn't say about Lithuania

Lithuanian tax rates, application to the French wealth tax (IFI), liberal professions, and the amicable settlement procedure are not addressed. The administrative list of April 29, 2026, classifies it as "IR – IF"; Article 2 makes no mention of inheritance or gifts.