The France-Syria convention was signed in Paris on July 17, 1998, and supplemented by an exchange of letters in Damascus on December 16, 2004. It entered into force on May 1, 2009, and applies only to income tax. Three rates apply: 15% for dividends, 10% for interest, and 15% for royalties. For information on penalties, see the French Treasury website cited below.
2009, 2010: two application dates
According to the BOFiP (BOI-INT-CVB-SYR, version of 12/09/2012), Law No. 2009-226 of 26 February 2009 authorized the approval, and Decree No. 2009-812 of 1 July 2009 published the text. Article 26 sets the application date: from 1 May 2009 for withholding taxes, and from 1 January 2010 for other income taxes. The list of 29 April 2026 (BOI-ANNX-000306, agreements in force on 1 January 2026) includes the convention with the mention "IR" alone: neither wealth nor inheritance tax. Syria has no entry in the list of conventions amended by the MLI (BOI-ANNX-000511, same date). The BOFiP commentary, in its 2012 version, does not mention suspension or denunciation and says nothing about the current status of the agreement.
Dividends: 15 %, or Beneficiary's State from 10 % of the capital
Article 10 § 2 a sets the limit at 15 % of the gross amount. Article 10 § 2 b waives this limit when the beneficial owner is a company that holds, directly or indirectly, at least 10 % of the capital of the paying company: the dividends are then taxable only in the State of which this beneficial owner is resident.
Royalties: an article added in 2004
The exchange of letters dated December 16, 2004, inserted Article 11 A between Articles 11 and 12. Paragraph 2 of this article caps the withholding tax at 15% of the gross amount of royalties. It also corrected references to Articles 21 and 22.
Maximum deductions and key rules
| Subject | Article | What the text says |
|---|---|---|
| Dividends | 10 § 2 a | 15 % of the gross amount |
| Dividends, beneficial owner company holding directly or indirectly at least 10 % of the capital | 10 § 2 b | Taxable only in the beneficiary's state |
| Interests | 11 § 2 | 10 % of the gross amount |
| Royalties | 11 A § 2 | 15 % of the gross amount |
| Capital gains, other assets | 12 § 4 | Taxable only in the state of the transferor |
| Salaries, exception | 14 § 2 | Stay of no more than 183 days per calendar year; employer not resident in the other State; expense not borne by a permanent establishment or fixed base |
| Pensions from previous employment | 17 § 1 | Taxable only in the State of residence, subject to Article 18 § 2 |
| Public salaries | 18 § 1 a | Taxable only in the paying state |
Who is a resident?
Article 4 § 2 applies to a natural person resident in both States. It considers, in order: the permanent home (then the center of vital interests), the habitual residence, the nationality, and finally the agreement of the competent authorities.
Tax credit: two systems depending on income
For France, Article 21 § 1 a provides for two cases. For income not mentioned in point ii, the credit is equal to "the French tax corresponding to this income," provided that the French resident is subject to Syrian tax on this income. For dividends, interest, and royalties (Articles 10, 11, and 11 A) and other listed income, the credit is equal to the tax paid in Syria, with this limit: "this tax credit may not exceed the amount of French tax corresponding to this income.".
Taxes concerned
Article 2, paragraph 3, cites "in particular," for France, income tax, corporation tax, and payroll tax. For Syria, it cites five categories, including tax on industrial, commercial, and non-commercial profits, tax on salaries and wages, and tax on income from movable and immovable property.
Sanctions: what the Treasury Directorate General says
According to the French Treasury's "Syria" page, published on March 19, 2026, the European Union eased its sanctions after December 8, 2024, and almost all sectoral sanctions were lifted (energy, transport, and the financial sector, in particular). The page specifies: "However, certain sectoral restrictions remain in effect," notably for equipment that could be used for internal repression, dual-use goods, items on the Joint Military List, certain technologies and software, and Syrian cultural property. Some asset freezes remain in place. No legal conclusions are drawn here; see the source cited at the end of the page.
What this page does not cover
The articles not cited above, the protocol, the exchange of information (Article 24), and Syrian law are not detailed. The current status of the convention is not addressed here; this should be verified with the relevant authorities.
Typical case (fictitious profile)
A company holds shares in a French company and receives dividends. Everything depends on the shareholding: at 10% or more of the capital, the dividends are taxable only in the recipient's country (Article 10 § 2 b); below this threshold, the 15% limit applies (Article 10 § 2 a). No amount is calculated.
Frequently asked questions
What is the withholding rate on interest payments between France and Syria?
Article 11 § 2 limits the withholding tax to 10 % of the gross amount of interest.
Are the royalties covered?
Yes, by article 11 A, added by the exchange of letters of December 16, 2004: 15 % of the gross amount.
Are inheritances covered?
No. The list of April 29, 2026 only mentions "IR", without wealth or inheritance.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, assists executives and families whose assets or business activities have ties to France and Syria. To discuss your situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- Tax treaties: countries linked to France
- Dividends paid to a non-resident: withholding tax of 12.8% %
- Double taxation: tax credit and effective tax rate
- French interest and obligations of a non-resident
- French pension of a non-resident: where is it taxed?
- Inheritance agreements: which countries with France
Official sources
- Text of the France-Syria Convention (1998): https://www.impots.gouv.fr/10conventionssyriesyrieconvention-avec-la-syrie-du-17071998-entree-en-vigueur-le-01052009fd5541pdf
- BOFiP doctrine, France-Syria convention (BOI-INT-CVB-SYR): https://bofip.impots.gouv.fr/doctrine/BOI-INT-CVB-SYR
- List of tax treaties (BOI-ANNX-000306): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
- List of agreements modified by the MLI (BOI-ANNX-000511): https://bofip.impots.gouv.fr/bofip/14854-PGP.html/identifiant=BOI-ANNX-000511-20260429
- Treasury Directorate General, economic sanctions, Syria: https://www.tresor.economie.gouv.fr/services-aux-entreprises/sanctions-economiques/syrie