The 2022 France-Moldova tax treaty: capped dividends, interest and royalties

The France-Moldova tax treaty caps withholding tax at 5 or 10 13 1/3 tax units on dividends, 5 1/3 tax units on interest, and 6 1/3 tax units on royalties. The official tax records classify it as income tax; Article 2, on the French side, refers to income tax, corporation tax, the CSG (General Social Contribution), and the CRDS (Contribution to the Repayment of the Social Debt). Signed in 2022, it has applied to withholding taxes since January 1, 2025. This page lists the articles covered and indicates what it does not address.

A text signed in 2022, implemented since 2025

The convention was signed in Chisinau on June 15, 2022, and entered into force on April 23, 2024. For withholding taxes, it applies to taxable amounts from January 1, 2025; for other income taxes, to years or fiscal years beginning on or after that date. The official tax register (BOI-ANNX-000306, dated April 29, 2026) classifies it as an income tax, without amendment. The tax authorities' commentary (BOI-INT-CVB-MDA, dated November 19, 2025) refers to the commentary on the convention with Luxembourg, which contains virtually identical provisions.

Maximum deductions and key rules

Residence: the housing facility first

Article 4, paragraph 2, determines, for a natural person resident in both States, the State where they have a permanent home, then the center of their vital interests, their habitual residence, their nationality, and finally the agreement of the competent authorities. For a company, the place of effective management is the determining factor (paragraph 3).

Proof of residence: a procedure explicitly stated in the text

Article 28 § 2 requires, in principle, the resident of the other State to present a certificate of residence form bearing the certification of the tax services of his State, in order to benefit from the reduced rates of articles 10 to 12. The competent authorities may derogate from this.

Eliminate double taxation

For the income covered by this text, France grants a tax credit against French tax (Article 21, paragraph 1). Moldova deducts the tax paid in France up to the amount of its own corresponding tax liability. Article 23 sets a three-year deadline, from the date of the first notification of the measure, for submitting a case to the mutual agreement procedure.

Dividends of €60,000: typical case (fictitious profile)

Situation. A French company, fictitious profile, directly holds at least 10 % of a Moldovan company throughout a period of 365 days including the payment date, and receives €60,000 in gross dividends.

Issue. She wants to know the maximum tax that Moldova can withhold at source under the convention.

Strategy. It applies the ceiling of Article 10 § 2 a), checks the conditions of detention, then obtains the certificate of residence of Article 28.

Result. The ceiling is €3,000 (5 % of €60,000), compared to €6,000 at the rate of 10 % if the holding condition were not met: a difference of €3,000. This figure is a maximum, not the tax due.

What this page does not cover

Moldovan tax rates, the clause for refusing benefits, termination procedures, and special regimes are not detailed. Wealth and inheritance are not addressed.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income: dividend, interest, royalty, gain, salary, pension.
• The percentage and duration of capital ownership.
• The number of days spent in each state.