The France-Mauritania tax treaty: income, inheritance, registration and stamp duty

The France-Mauritania convention of November 15, 1967, does not set any specific limit on withholding tax on dividends, interest, or royalties. However, it does regulate inheritance tax, registration fees, and stamp duty, with a threshold of 183 days for employees, calculated over the fiscal year. This page lists the articles read and indicates what it does not cover.

A text from 1967, accompanied by two exchanges of letters

The convention was signed in Nouakchott on November 15, 1967, along with a protocol and an exchange of letters of the same date. The heading of the published text indicates an entry into force on March 1, 1969. An exchange of letters dated March 8, 1994, concerns contracts performed in part by a permanent establishment located in the other State (Article 10). The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies the convention among those concerning income, inheritance, and registration duties. The BOFiP page consulted (BOI-INT-CVB-MRT, version of February 24, 2021) makes no mention of suspension or denunciation; the list contains no notes on the line. Mauritania is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511).

Mauritania: Maximum Detentions and Key Rules

Home: the permanent dwelling place

Article 2 defines domicile as the place of permanent home (center of vital interests), then the longest stay, then, in the case of stays of equal duration, nationality, then the agreement of the authorities.

Inheritance: three rules

Article 27 addresses the inheritance tax of each state. The text distinguishes between:

• the buildings inheritance tax only in the State where they are located (article 28); ;
• tangible personal property : only in the State where they are actually located on the date of death, boats and aircraft in the State of registration (Article 31); ;
• other assets : only in the State where the deceased was domiciled at the time of death (Article 32).

The BOFiP specifies that the agreement is written on the same model as the one concluded with Mali on September 22, 1972. The status of the agreement with Mali is dealt with on its own page.

Eliminating double taxation in France

Article 26 excludes from the French income tax base income exclusively taxable in Mauritania. For income under Articles 13, 15, and 18 subject to tax on investment income in Mauritania, Article 26, paragraph 3(a), provides for a deduction of 25 % for dividends and 12 % for other income in this category. Interest under Article 19 entitles the taxpayer to a tax credit of 16 %, which can be offset against income tax or corporation tax (paragraph 3(b)).

What the page doesn't say about Mauritania

Capital gains (included in the taxes referred to in Article 8; the text read does not contain an express rule of distribution), registration and stamp duties of Articles 35 and 36, the amicable procedure, Mauritanian internal taxation, the protocol, Article 23 on liberal professions and denunciation are not detailed.

What changes depending on your situation

• The location of your permanent home.
• The number of days spent in each state during the Mauritanian fiscal year.
• The category of Mauritanian income: dividend, interest or other.