The France-Central African Republic tax treaty: what the tax authorities' commentary establishes

In the passages we have read, the 1969 convention does not set any maximum percentage for withholding tax. It allocates the right to tax according to the nature of the income: real estate in the country where it is located, interest according to the type of debt, and, for income from French sources received by Central African residents, the general income tax only in the Central African Republic (Article 26 § 4). This document is based on the BOFiP commentary (version of 12/09/2012), not on the signed text, and describes what it does not address.

A text from 1969, supplemented by an exchange of letters

The convention was signed in Bangui on December 13, 1969, with a protocol and an exchange of letters dated December 13 and 16. It entered into force on March 1, 1971, following the law of December 18, 1970, and the decree of May 18, 1971. The administrative list (BOI-ANNX-000306, dated April 29, 2026) maintains it in force, without amendment, and mentions income, inheritances, and registration fees.

It applies to metropolitan France, overseas departments and the Central African territory (Article 1 § 2).

Tax domicile: the permanent home

For a natural person, Article 2 § 1 refers to the permanent home, which the commentary designates as the center of vital interests. Failing that, the commentary refers to the principal residence or nationality, without specifying which applies.

Maximum deductions and key rules

The 2012 BOFiP commentary cites a withholding tax of 25% (Article 119 bis of the French General Tax Code). The current rate for a non-resident individual is 12.80% as of January 1, 2026, subject to tax treaties (impots.gouv.fr, "My Dividends"). The tax treatment of dividends paid to a non-resident is covered on our dedicated page.

Buildings and equipment rental: the current situation

The classification of property as real estate is determined according to the legislation of the state where the property is located (Article 4). Real estate income is taxable only in that state (Article 9). Article 20 applies the same principle to equipment of a real estate nature; other industrial, commercial, or scientific equipment falls under the jurisdiction of the beneficiary's residence.

Interest and attendance fees

Interest on negotiable bonds follows the issuer's tax domicile (Article 13, paragraph 1). Interest on non-negotiable debt follows the creditor's tax domicile, and each State may impose a withholding tax if its domestic legislation so provides (Article 19). For interest from French sources received by a person domiciled in the Central African Republic, Article 26, paragraph 4 applies (see table). For directors' fees, the Central African withholding tax may be fully offset against the French withholding tax, upon proof of tax paid in the Central African Republic (Article 18).

Central African taxes targeted

Article 8, paragraph 3, lists the following Central African taxes: industrial and commercial profits, profits from non-commercial professions, salaries, wages, pensions and annuities, income from securities and movable capital, land taxes, general income tax and flat-rate tax on personal income, and additional centimes. The commentary does not list the French taxes concerned and does not detail inheritance taxes or registration fees, which it mentions in its introduction.

What this sheet does not cover

Salaries, pensions, capital gains excluding real estate, the general method for eliminating double taxation, inheritance and registration rules, Central African tax rates, and the length of stay for missions are not addressed. The commentary refers to another convention for other clauses; these references are not used.

What changes depending on your situation

• Your tax residence as defined in Article 2.
• The nature of the income: real estate, dividend, interest, attendance fee, equipment rent.
• The type of debt, negotiable or not.
• The location of the property.

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