The France-French Polynesia tax treaty: a 1957 text on income from movable capital.

According to the BOFiP commentary, the 1957 convention between the French State and French Polynesia was concluded "to avoid double taxation on income from movable capital." The administrative list categorizes it under "Taxes on income from movable capital." The text itself, published by the tax authorities, aims to eliminate double taxation and organize mutual administrative assistance for this income. Neither the text nor the commentary sets a tax rate. A 2009 agreement governs the exchange of information. This fact sheet is based on the text of the convention, the BOFiP commentary (version of September 12, 2012), and the list of April 29, 2026. It is intentionally brief: it only states what these sources establish.

A text from 1957 concerning the former French Establishments in Oceania

The convention was signed on March 28 and May 28, 1957, in Paris and Papeete, between the French State and the territorial collectivity then known as the French Establishments in Oceania. A protocol forms an integral part of it. The decree of August 1, 1957, approved and published it in metropolitan France (Official Journal of August 15, 1957). It entered into force on September 19, 1957.

French Polynesia is an overseas collectivity governed by Article 74 of the Constitution. It has fiscal jurisdiction under Article 13 of the Organic Law of 27 February 2004.

The tax on distributions was introduced in 1956

A decree of December 28, 1956 approved a resolution of the territorial assembly of November 20, 1956 establishing a distribution tax, which came into force on January 1, 1957. Since that date, according to the commentary, French Polynesia belongs to the territories where a tax on profit distributions applies (article 115 ter of the CGI).

What the 1957 text stipulates

The text of the agreement is published by the tax authorities. It does not specify the rate of the proportional tax or the rate of the progressive surtax.

The BOFiP commentary adds a point on distributions made since 1957 by metropolitan companies whose profits come partly from operations located in Polynesia: income tax at the common law rate only applies to the portion of distributions whose taxation is reserved for metropolitan France by the convention.

The exchange of information: the 2009 agreement

According to the commentary, the exchange of information was previously limited to the taxes covered by the convention, and the Mutual Administrative Assistance in Tax Matters Agreement of December 29, 2009, was concluded to supplement Article 13. This agreement was approved by the Organic Law of April 19, 2011. The list places it under "Exchange of Information" (specific agreement of December 29, 2009, Official Journal of April 20, 2011). The commentary does not describe its content. The 1957 text itself provides, in Article 12, for an exchange of information between tax authorities, covered by confidentiality.

What this sheet does not cover

Royalties, capital gains, inheritances, Polynesian income taxes, the general definition of a resident, the content of the 2009 agreement, and the general method for eliminating double taxation are not included in the 1957 text read here. Therefore, this document does not describe them. The list dated April 29, 2026, only mentions the 1957 text and the 2009 agreement.

What changes depending on your situation

• The nature of your income: the comment and the list link the agreement to income from movable capital.
• Your tax residence and that of the distributing company.
• The portion of distributed profits that comes from operations in Polynesia.

A text must be read in light of the facts in your case; no result is guaranteed in advance.