The France-Qatar tax treaty: a 1990 text with no expiry date, amended in 2008 and then by the MLI

The tax treaty between France and Qatar was signed on December 4, 1990. It has no time limit: either state may terminate it with at least six months' notice, effective at the end of a calendar year. It reserves dividends, interest, and royalties for the state of the beneficiary, without tax, but only if that state is the beneficial owner. This page presents what we have been able to find in the consolidated text and explains what it does not cover.

A 1990 agreement, letters from 1993, a 2008 addendum, and the MLI

The original text. The convention was signed on December 4, 1990, with an exchange of letters on the same day. It entered into force on December 1, 1994 (Law No. 91-1392 of December 31, 1991, Decree No. 94-1107 of December 19, 1994). The administrative list of conventions (BOI-ANNX-000306, dated April 29, 2026) classifies it as relating to income tax, wealth tax, and inheritance tax.

The letters from 1990 and 1993, and the amendment from 2008. The list mentions an exchange of letters dated January 12, 1993, and an addendum signed on January 14, 2008, which came into effect on April 23, 2009 (Law No. 2009-228 of February 26, 2009, Decree No. 2009-932 of July 29, 2009). French official sources do not agree on the exchange of letters: the administrative list cites the one dated January 12, 1993, while the BOFiP page of the agreement cites the one dated December 4, 1990. We are not arbitrating between these sources; verification with the original sources is necessary. The sources consulted do not describe what the addendum changed, nor does the page itself mention it.

The MLI. The multilateral convention applies there: for withholding taxes, on sums paid from 1 January 2021; for other taxes, on periods beginning from 1 October 2020. It entered into force on 1 January 2019 for France and on 1 April 2020 for Qatar.

Articles read, in a table

Pensions: two systems depending on the source of payment

This point distinguishes this text. Article 14, paragraph 1, provides that, subject to Article 15, pensions and similar remuneration paid to a resident in respect of previous employment "are taxable only in that State." However, paragraph 2 sets aside this rule for pensions and other sums paid under the social security legislation of a State: they are taxable in that State, the one that pays them.

The two paragraphs refer to payments from different sources: the former employment on the one hand, and social security legislation on the other. Article 15, entitled "Public Service," is reserved by paragraph 1; the page does not elaborate on it.

Dividends, interest, royalties: a state rule for the beneficiary, subject to conditions

Article 8, paragraph 1, stipulates that dividends paid by a company resident in one State to a resident of another "are taxable only in that other State if the person receiving the dividends is the beneficial owner thereof." The text does not specify a withholding tax percentage. The same principle applies to interest (Article 9, paragraph 1) and royalties (Article 10, paragraph 1). Royalties include, in particular, copyright, patent, and trademark royalties.

Two limitations are outlined in the text. If the beneficial owner conducts business through a permanent establishment or fixed base in the debtor's state and the participation, claim, or right is attributable to it, the rule does not apply; the articles concerning profits or self-employment then take precedence. Furthermore, a Qatari resident who receives dividends from a French company can claim a refund of the withholding tax (Article 8, paragraph 2).

Who is a resident?

Article 4, paragraph 1, defines, for France, any person liable for tax by reason of their domicile, residence, or place of management, and, for Qatar, any person "domiciled or having their place of management in Qatar." For an individual resident in both States, paragraph 2 lists, in order: permanent home, then center of vital interests; habitual residence; nationality; and the agreement of the competent authorities.

Salaries, professors and researchers

Regarding salaries, Article 13, paragraph 2, allows taxation in the state of residence if three conditions are met: a stay in the other state not exceeding a total of 183 days "during the tax year in question," an employer who is not a resident of the other state, and remuneration not borne by a permanent establishment or fixed base of the employer in that state. For professors and researchers, paragraph 3 establishes a period of twenty-four months, calculated from the date of first arrival. The substantive content of this paragraph is found in the text.

Capital gains, real estate and inheritances

Capital gains from real estate are taxable in the state where the property is located (Article 11, paragraph 1(a)). The same applies, subject to a condition specified in the text and which should be reviewed, to shares in a company whose assets consist of more than 80% of real estate (paragraph 1(b)). A substantial shareholding, entitling the holder to more than 25% of the profits, is taxable in the state of residence of the company (paragraph 2). Other assets are taxed in the state of residence of the transferor (paragraph 4).

Income from real estate is taxable in the State where the property is located (Article 5 § 1). Income not covered by any preceding article is taxable only in the State of residence of the beneficial owner (Article 16 A).

For inheritances, real estate is subject to tax only in the State where it is located (Article 18 § 1); movable property attached to a permanent establishment or a fixed base, only in the State where it is located; other movable property, including securities and deposits, only in the State of residence of the deceased at the time of death.

Double taxation: the French tax credit and the clause in paragraph 3

Article 20 addresses the elimination of double taxation through a tax credit that can be offset against French tax. Paragraph 3 adds a clause preventing double exemption: to avoid double exemptions, each State taxes income, excluding dividends and pensions, that the convention attributes to the other State but that the latter does not include in its taxable base. Excluded are States and their public entities, Qatari citizens, and companies more than 50% owned by Qatari citizens. The detailed calculation of the credit is not included here.

An agreement without a limited duration

Article 24 § 3 provides that the convention has no end date: each State may denounce it through diplomatic channels, with at least six months' notice, for the end of any calendar year after 1995. It also contains an amicable procedure and, in Article 21 A, an exchange of information: information cannot be refused solely on the grounds that it is held by a bank, a representative, an agent or a trustee.

The preliminary clause on the right to benefits denies a benefit obtained through an arrangement of which it was one of the main objects, except in cases where the benefit is in conformity with the object and purpose of the agreement.

What this page does not cover

Wealth (Article 17) and the real estate wealth tax, the content of the 2008 amendment, the detailed mechanics of the tax credit, and the Qatari concept of an individual's tax residence are not addressed. Only one page from the Qatari tax administration concerning withholding taxes has been included here.

Royalties received from Qatar: a numerical example (fictitious profile)

Situation. A consultant residing in France (fictitious profile) receives €40,000 in royalties from a company established in Qatar. She has neither a permanent establishment nor a fixed base there. Hypothesis: these royalties fall under the condition set by the Qatari website (services rendered in whole or in part in Qatar); this connection is not verified for this fictitious profile.

Issue. The Qatari tax authorities state that a withholding tax of 5 % applies to the total amount of royalties paid to non-residents without a permanent establishment, for services rendered in whole or in part in Qatar, and that a refund is possible when a tax treaty in force supports the claim. Article 10 § 1 of the treaty reserves the royalties for the State of the resident beneficial owner.

Strategy. She calculates the deduction, then has the refund request examined on the prescribed form, with the documents that establish her residence and her status as beneficial owner.

Result. The withholding is €2,000 and the net amount received is €38,000, pending reimbursement. This calculation does not guarantee the outcome of the application; it depends on the terms of the legislation and Qatari procedure.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income: dividend, interest, royalty, salary, pension, gain.
• The origin of a pension: previous employment or social security.
• Your status as a beneficial owner and the existence of a permanent establishment or fixed base.
• The nature and location of your assets, for inheritance purposes.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.