France-Taiwan tax arrangement: Article 77 of the amending finance law for 2010

France does not have a tax treaty with Taiwan. The relevant framework is domestic law: Article 77 of Law No. 2010-1658 of December 29, 2010, amending the 2010 Finance Law. The BOFiP (Official Bulletin of Public Finances) lists Taiwan under the heading "Taiwan (Territory of)," with the notation "IR" (income tax). Decree No. 2010-1721 of December 30, 2010, sets the effective date as January 1, 2011.

What the list and the BOFiP say

List BOI-ANNX-000306 (version of April 29, 2026, agreements in force as of January 1, 2026) indicates for Taiwan: no convention, reference to Article 77, tax referred to as "IR" (income tax), no amendment, no note. Taiwan is not included in the list of conventions modified by the multilateral convention (BOI-ANNX-000511, same date).

The commentary BOI-INT-CVB-TWN (version of September 12, 2012) refers to Article 77 for the territory where tax legislation administered by the Taiwan Tax Agency applies. It provides the application dates set by the decree of December 30, 2010:

Why a domestic legal mechanism

The article is entitled "Measures to Avoid Double Taxation and Prevent Tax Fraud and Evasion in Relations with the Territory of Taiwan." The report of the Senate Finance Committee (No. 166, tabled on December 13, 2010) comments on the draft text, where the article was number 32. It states that a convention would amount "ipso facto to recognition by France of Taiwan's status as a State." It therefore presents the text as a "quasi-convention" implemented through domestic law, with the Taiwanese authorities introducing equivalent provisions.

What the Senate report on the project describes

The report compares the draft to the OECD model convention. These points are those of the 2010 draft: the final text of Article 77 is verified before any decision is made.

The report also indicates an exchange of information between the authorities of both parties.

What the instructions for form 2047 say

The instructions for form 2047 (income 2025) mention Taiwan in the list entitled "tax credit equal to the amount of French tax" (box 8TK). They also mention it in the table of "rates applicable to net income after tax withheld at source," on the line "TAIWAN (TERRITORY OF) div. 11.1%, int. 11.1%." This page does not interpret these percentages and does not compare them to the rate of 10.% mentioned in the Senate report.

A non-application order is planned

According to the Senate's law implementation tracking page, a decree could be issued finding that the Taiwanese tax authorities are not applying equivalent provisions. The article would then cease to apply on the following January 1st. The existence of such a decree should be verified with the tax authorities.

Taiwanese dividend to be declared: typical case (fictitious profile)

Situation. Claire, a fictitious profile, is a tax resident of France. A Taiwanese company pays her a dividend.

Issue. She wants to know how to declare it and whether the tax levied in Taiwan is deductible.

Strategy. She notes the gross amount and the tax withheld on the receipt, reads the 2047 notice (Taiwan is listed in box 8TK) and checks the current text of article 77.

Result. No figures are calculated: the withholding rate and the credit depend on the applicable legislation and individual circumstances. No tax conclusions are drawn for this profile.

What this page does not cover

It does not reproduce the final text of Article 77: withholdings, residency, and tax credits are determined by law. It does not address Taiwanese tax law, inheritance, or social security. Local tax matters are determined by consulting a professional based in Taiwan. French tax law is covered in our sections on tax residency, the 2047 tax return, and foreign bank accounts.

What changes depending on your situation

• Your tax residence: France, Taiwan, or a situation in between.
• The nature of the income: dividend, interest, royalty, capital gain, salary.
• The text in force on the date of the income.

The rule depends on your situation. No results are guaranteed.