The France-United Kingdom tax treaty, point by point

The tax treaty between France and the United Kingdom concerning income tax and capital gains was signed in London on June 19, 2008. It entered into force on December 18, 2009, and replaced the treaty of May 22, 1968. Two clauses are of particular interest to expatriates: the six-year tax period for capital gains and the anti-remittance clause. This page outlines the most important articles and explains what they do not cover.

A text from 2008, an MLI list

The convention was signed in London on June 19, 2008 and published in France by decree no. 2010-20 of January 7, 2010. It entered into force on December 18, 2009. The authorising law is no. 2009-1470 of December 2, 2009.

The United Kingdom is included in the administrative list of conventions amended by the Multilateral Convention (MLI): BOI-ANNX-000511, dated April 29, 2026. This list indicates an effective date in France of January 1, 2019, for taxes withheld at source and July 1, 2019, for other taxes. The tax authorities have published a consolidated version of the convention as amended by the MLI. Before Article 1, they have inserted a clause entitled "right to the benefits of the convention," based on the principal purpose criterion: a treaty benefit may be denied if one of the principal purposes of an arrangement is to obtain it. They have also amended Articles 5, 10, 12, 13, 23, and 26, and removed paragraph 6 of Article 11. Articles 4(2), 14, and 29, presented below, remain unchanged. The administration's comment (BOI-INT-CVB-GBR-10, published on September 12, 2012) predates the MLI.

The essential rules

Who is a resident?

Article 4, paragraph 2, first considers the permanent home: a person resident in both States is deemed to be a resident of the State where they have such a home. The following criteria are found in the text, in the order it specifies.

French tax residence is another concept, discussed on our page about leaving France.

Dividends

Article 11 taxes dividends in the recipient's state of residence. The state of the distributing company may also tax them, up to a limit of 15% of the gross amount. The text provides for an exemption (0% of the capital) for certain companies holding at least 10% of the capital (§ 1 c), the conditions for which are not detailed here. Specific cases should be reviewed before making any decisions.

Capital gains: the principle and the six-year clause

The principle. For gains from the disposal of property other than that referred to in paragraphs 1 to 4 of Article 14, paragraph 5 reserves them for the State of which the transferor is a resident. Certain securities fall under paragraph 2: shares not listed on a regulated market, units or rights deriving their value or the majority of their value from immovable property are taxable in the State where that property is situated.

The six-year clause. Paragraph 6 adds a caveat: Paragraph 5 does not affect the right of a Contracting State to levy, in accordance with its laws, a tax on "gains from the alienation of any property by a person who is, and has been at any time during the preceding six fiscal years, a resident of that Contracting State." It also applies to a person who is a resident of that State at any time during the fiscal year in which the property is alienated.

The paragraph refers to the state's domestic legislation that imposes the tax; it does not itself assign a tax base or a rate. Its relationship with the French exit tax is not established: do not infer from this that they are cumulative or mutually exclusive.

The anti-remittance clause

Article 29 applies to residents who are taxed only on the portion of income transferred or received in their state of residence. According to paragraph 1, the tax advantage granted in the source state applies only to the portion of income taxed in the other state: the limitation is proportional, not an all-or-nothing situation. This provision does not apply to income covered by Articles 7 (business profits) and 11 (dividends). Paragraph 2 follows the same logic for the exemption of gains under Article 14: it applies only to the portion of gains taxed in the first state.

The administration's commentary describes it for British residents subject to the "remittance basis" and requires supporting documentation from the British authorities. The text of the convention does not use this expression.

Since April 6, 2025, the UK domicile-based and remittance-based tax regime has been replaced by a residence-based regime. The application of the clause to this new regime is assessed on a case-by-case basis. Our FIG regime page explains the UK reform.

British people settling in France

Article 29, paragraph 3, applies to British citizens without French nationality who have become residents of France. For five years, their assets located outside France are not subject to the wealth tax. This rule applies again if they have not resided in France for at least three years.

The text refers to the wealth tax (ISF). The tax authorities' commentary, which dates from 2012, does not address subsequent changes to the ISF. Its application to the real estate wealth tax (IFI) has not been established.

Inheritance: a separate agreement

The administrative list of conventions mentions, for the United Kingdom, a convention of 21 June 1963 on successions, distinct from the 2008 convention (BOI-ANNX-000306, version of 29 April 2026). Its content is not presented here.

What this page does not cover

Interest, royalties, capital gains, salaries, pensions and the elimination of double taxation are not presented here, nor is the content of the 1963 convention. These articles can be found in the consolidated text.

Numerical example (fictitious profile)

Situation. A UK resident, fictitious profile, holds shares in a French company which pays him €80,000 in gross dividends per year.

Issue. He wants to know what amount of tax the State can withhold from the distributing company.

Strategy. He starts with the ceiling of article 11, then has his resident status and the specific cases of the text examined.

Result. The 15 % cap on the gross amount represents €12,000 out of €80,000 (€80,000 × 15 %). This amount is a cap: it does not indicate the actual withholding rate applied.

What changes depending on your situation

• Your residence as defined in the convention, which depends on your permanent home.
• Your residency status in either state during the previous six tax years, for the six-year clause.
• Your UK tax regime, for the anti-remittance clause.
• The nature of the income: dividend, capital gain, other income.
• The "right to benefits" clause and other MLI amendments that affect your situation.

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