The France-Madagascar tax treaty: three sets of ceilings on dividends, interest and royalties

The France-Madagascar convention sets withholding tax ceilings of 15 or 25 on dividends, 15 on interest, and 10 or 15 on royalties. The official list classifies it as an income tax treaty; Article 2, from the French perspective, addresses income tax and corporate tax. From the French perspective, it generally exempts income taxable in Madagascar. This page presents the articles included in the official text and explains what it does not cover.

A text from 1983, which came into force on October 1, 1984

The convention was signed in Tananarive on July 22, 1983, following two exchanges of letters. It entered into force on October 1, 1984, and replaced the convention of September 29, 1962 (BOFiP, BOI-INT-CVB-MDG). The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it among the conventions on income (income tax only), without amendments. Madagascar is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511).

Madagascar: Maximum retention limits and key rules

Dividends, royalties: a numerical example (fictitious profile)

Situation. A Malagasy company, fictitious profile, receives €30,000 gross in dividends from a French company of which it directly owns 30 % of the capital, and €20,000 gross in royalties from copyright.

Issue. She wants to know the maximum amount that France can retain.

Strategy. It applies articles 10 and 12, then verifies direct ownership and beneficial ownership status.

Result. The cap is €4,500 on dividends (15 %s of €30,000) and €2,000 on royalties (10 %s of €20,000). For a beneficiary with less than 25 %s of direct ownership, the cap on dividends would be €7,500 (25 %s). This calculation shows the maximum allowed by the treaty, not the actual tax due.

Residence and employees: 183 days in the fiscal year

Article 4, paragraph 1, defines a resident as any person liable for tax by reason of their domicile, residence, registered office, or a similar criterion. For an individual resident in both States: permanent home, center of vital interests, habitual residence, nationality, and then agreement of the authorities.

Article 15 considers a stay not exceeding 183 days in total during the tax year in question, with an employer not resident in the other State, and an expense not borne by a permanent establishment or fixed base. Article 15 does not define the tax year. Public pensions are taxable only in the paying State (Article 19, paragraph 2).

Tax exemption or credit in France

Article 22 distinguishes between two cases. For income covered by Articles 10, 11, 12, 16, and 17, France grants a tax credit equal to the Malagasy tax paid, capped at the corresponding French tax. For other income, France exempts it provided it is taxable in Madagascar under its domestic legislation. The rate applied to other income takes into account the total income.

What the page doesn't say about Madagascar

Malagasy taxes, amicable settlement procedures, assistance with tax collection, tax clearance certificates, and inheritances are not addressed. Article 2 does not cover wealth or inheritances.

What changes depending on your situation

• Direct ownership of 25 % of the capital, which reduces the ceiling from 25 % to 15 %.
• The nature of the royalty, which determines 10 % or 15 %.
• The Malagasy fiscal year and the number of days spent in each state.
• The taxable nature of income in Madagascar, which decides between exemption and tax credit.