The tax treaty of September 22, 1972, between France and Mali no longer applies to income earned on or after March 5, 2024, nor to estates opened on or after that date. France suspended it on March 5, 2024; according to note 3 of the administrative list, this suspension, from March 5 to December 31, 2024, is followed by denunciation, notified by Mali, effective January 1, 2025. This page summarizes the information in the administrative list and the BOFiP (Official Bulletin of Public Finances), and then reiterates the provisions of the 1972 treaty for prior situations.
Key dates
| Date | Event | Source |
|---|---|---|
| September 22, 1972 | Signed in Paris; effective January 1, 1975 | BOFiP, text header |
| December 5, 2023 | Mali notifies France of the cessation of application of the convention | BOFiP |
| March 5, 2024 | France suspends the convention, by way of reciprocity (Article 55 of the Constitution) | BOFiP |
| December 31, 2024 | End of suspension | BOFiP list |
| January 1, 2025 | The denunciation notified by Mali takes effect (Article 44: notification received between January 1 and June 30, effect on January 1 of the following year; BOFiP: the Malian notification of December 2023 only takes effect on January 1, 2025) | Text from 1972, BOFiP, list (note 3) |
Mali: Maximum detentions and key rules, what remains
| Subject | Rule according to the BOFiP (version of September 4, 2024) |
|---|---|
| Income tax | The agreement no longer applies to income acquired on or after March 5, 2024. BOFiP tolerance: salaries, "self-employment" income, and pensions are considered covered if acquired up to and including April 30, 2024; profits: coverage is maintained if fiscal years beginning no later than March 4, 2024, do not exceed 12 months. |
| Successions | It ceases to apply to estates opened on or after March 5, 2024. |
| Registration and stamp | It ceases to apply to acts and judgments occurring on or after March 5, 2024. |
| Dividends and interest from French sources | Taxable in France under the standard legal conditions |
| French source royalties | The exemption from withholding tax no longer applies (the 1972 text reserved it to the State of the beneficiary, article 20 § 2) |
| Capital gains on equity interests (substantial participation) | Sales made from March 5, 2024 onwards by Malian residents: taxable in France |
| Malian income of a French resident | Malian taxes on income acquired from March 5, 2024 onwards do not give rise to any tax credits or treaty deductions in France; Malian tax levied after March 5, 2024 can be deducted according to common law (BOI-BIC-CHG-40-30, BOI-RPPM-RCM-20-10-20-60). |
| Mutual agreement procedure | Can no longer be implemented from 5 March 2024; ongoing procedures closed |
What the 1972 text stipulated
These rules only apply to income acquired before March 5, 2024 (subject to the tolerances of the BOFiP) and to estates opened before that date.
- Employees. The 183-day threshold was measured during the tax year in question (Article 22 § 2), with two other cumulative conditions.
- Inheritance. Real estate was subject to inheritance tax only in the state where it was located (Article 28). Property not covered by Articles 28 to 31 was subject to inheritance tax only in the state of the deceased's domicile (Article 32).
- Malian investment income of a French resident. Article 26 § 3 a) stipulated, for investment income from Malian sources taxed in Mali pursuant to Articles 13, 15 and 18, a deduction of 25 % for dividends and 12 % for other categories of such income.
What the page doesn't say about Mali
The other specific rules of the BOFiP, Malian internal taxation, French taxation applicable without a treaty to each income (see our pages on non-residents), the fate of procedures already initiated and registration fees are not detailed.
What changes depending on your situation
- The acquisition date of each income: before or on or after March 5, 2024.
- The date the estate was opened.
- Your tax residence, French or Malian, and the nature of your income.
- The tolerance measures on the BOFiP page.
Frequently asked questions
What is happening with the tax treaty between France and Mali?
France suspended it from March 5, 2024 following notification from Mali on December 5, 2023. The administrative list (note 3) indicates that this suspension is followed by denunciation from January 1, 2025.
Does the convention still apply to inheritances?
It ceases to apply to estates opened on or after March 5, 2024.
Can a French resident claim a tax credit for Malian taxes?
For income acquired from March 5, 2024 onwards, the BOFiP indicates that no conventional tax credits or deductions are available in France.
Take stock of your situation
Balmont Conseil, a firm established in Lyon for nearly 14 years, welcomes you if your assets or business are divided between France and Mali. 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
- French tax residence: the 3 criteria (art. 4 B)
- Leaving France: exit tax, tax residence, procedures
- Double taxation: tax credit and effective tax rate
- Dividends paid to a non-resident: withholding tax of 12.8% %
- Inheritance agreements: which countries with France
- Foreign address: inform the tax authorities of your departure
Official sources
- BOFiP doctrine, France-Mali agreement (BOI-INT-CVB-MLI), version of September 4, 2024: https://bofip.impots.gouv.fr/doctrine/BOI-INT-CVB-MLI
- Text of the agreement of September 22, 1972 (impots.gouv.fr): https://www.impots.gouv.fr/sites/default/files/media/10_conventions/mali/mali_convention-avec-le-mali_fd_1919.pdf
- List of tax treaties (BOI-ANNX-000306), note (3): 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
