For someone living in Russia, the French tax framework is defined by three elements. The 1996 tax treaty has been partially suspended since August 8, 2023: French-source income of a Russian resident is subject to French domestic law. Russia is on France's list of non-cooperative states and territories. According to the French Treasury (DG Trésor), European Union sanctions apply to nationals of a member state both inside and outside the Union. The criteria for Russian tax residency, the income tax scale, and the tax rates for wealth and inheritance are not detailed here: they are governed by the Tax Code of the Russian Federation and should be verified with the Federal Tax Service.
A partially suspended convention: the effect for a resident of Russia
According to the French Official Tax Bulletin (BOI-INT-CVB-RUS, version of October 23, 2024), Articles 5 to 22 and 24 of the Convention of November 26, 1996, and points 2 to 9 of the Protocol have been suspended since August 8, 2023, by Russia and, reciprocally, by France. Details can be found on our page about the Convention. For a person domiciled in Russia who receives income from French sources, the BOFiP states:
- dividends: taxation according to domestic law, with a withholding tax at the rate provided for in BOI-RPPM-RCM-30-30-10-20 for natural persons; ;
- interests: internal law of each State, exclusive taxation in the State of residence no longer applies; ;
- French-source salaries and pensions: withholding tax; ;
- Real estate wealth: the convention ceases to apply for tax years from 1 January 2024, the territoriality rules of the IFI being governed by domestic law.
This page does not specify any withholding rates: these rates are found in the official tax regulations (BOFiP) as of the payment date. Some exceptions apply to earlier periods: dividends decided on or before August 7, 2023, and salaries and pensions for periods ending on or before September 30, 2023.
French tax domicile and Article 4 of the convention
Leaving France is not sufficient to change one's French tax residence: Article 4 B of the French General Tax Code (CGI) considers the home or principal place of residence, professional activity, and center of economic interests, and only one criterion is required (BOFiP BOI-IR-CHAMP-10). Article 4 of the tax treaty, which addresses dual residence, is not included in the list of suspended articles. The BOFiP does not specify its practical implications: this page does not resolve the issue.
Russia on the list of non-cooperative states
The appendix to the 2027 draft budget law indicates that 11 states and territories are included on the French list of non-cooperative states and territories, including Russia, following the decree of April 15, 2026. The BOFiP (Official Bulletin of Public Finances) specifies that Russia has been on the list since the decree of February 16, 2024. Consequently, the deduction from taxable income of sums paid to Russian individuals is, in principle, excluded, unless proof is provided that the expenses correspond to genuine transactions that are neither abnormal nor excessive (Article 238 A of the French General Tax Code). The list is verified on the date of the transaction.
European Union sanctions: what the French Treasury Directorate General says
The French Treasury's "Russia Sanctions" page (published on March 19, 2026) indicates that Regulations 833/2014 and 269/2014, among others, apply, including the 19th package adopted on October 23, 2025. According to this page, these regulations apply in particular to any natural person who is a national of a Member State, "inside or outside the territory of the Union," and to any economic activity carried out wholly or partly within the Union. The 19th package includes, according to the page, bans on transactions with five new Russian banks. The page does not address payments by individuals. The details of the sanctions applicable to your transactions are not described here; please verify this with the French Treasury and your bank on the date of the transaction.
Social protection: what the Cleiss says
The Cleiss fact sheet "Social Protection in Russia" is labeled 2025. It does not mention any bilateral social security agreement with France. It indicates that foreigners on temporary stays are not covered by mandatory pension insurance. As of January 1, 2025, the employer contribution is 30 % up to a ceiling of 2,759,000 rubles, and then 15.1 % above that. Current rates can be verified with Cleiss. For health insurance coverage for a French citizen residing outside of France, see our page on the Caisse des Français de l'étranger (French Nationals Abroad Fund).
Local formalities as per the Travel Advice sheet
The French Ministry for Europe and Foreign Affairs' travel information sheet on Russia states that foreign nationals must register with the local office of the Ministry of Internal Affairs "within 7 working days of arrival at their place of stay." The sheet exists in two versions that differ regarding bank cards. The online version, which has blank update fields, states: "Major credit cards are accepted." The PDF version, whose "Payment Methods" section is dated October 16, 2026, states: "Credit cards issued in Europe are no longer accepted." This page does not provide a definitive answer: check the information for your departure date.
What this page does not cover
The criteria for Russian tax residency, income tax rates, withholding taxes on dividends and capital gains, wealth tax, inheritance tax, local savings tax, and residence permits are not detailed here. These matters fall under the Tax Code of the Russian Federation (Part II) and regulations concerning the residency of foreigners, which should be verified with the Federal Tax Service and the Russian authorities. French obligations, particularly the declaration of accounts held abroad, are addressed in our pages on tax residency and form 3916.
What changes depending on your situation
- Your tax residence: France, Russia, or a situation in between.
- The nature of your French-source income: dividends, interest, salaries, pensions, rents.
- The date of the distribution decision or the period concerned in relation to the tolerance dates.
- Your counterparties and your banks with regard to the sanctions.
- Your residency status, which determines your eligibility for Russian pension insurance.
The rule depends on your situation. No results are guaranteed.
Frequently asked questions
Does the France-Russia tax treaty still apply to a resident of Russia?
Only partially: Articles 5 to 22 and 24 have been suspended since August 8, 2023, with tolerances for certain earlier periods.
Is there a social security agreement between France and Russia?
The Cleiss fact sheet for 2025 does not mention any.
Is Russia on the French list of non-cooperative states?
Yes, according to the annex to the draft finance law for 2027 (decree of April 15, 2026), and according to the BOFiP since the decree of February 16, 2024.
Take stock before you settle in
Balmont Conseil, a firm based in Lyon for nearly 14 years, advises executives and families whose assets or business activities have ties to France and other countries. 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
- France-Russia tax treaty: partial suspension
- Leaving France: exit tax, tax residence, procedures
- French tax residence: the 3 criteria (art. 4 B)
- Foreign bank account or contract: what needs to be declared?
- Wealth tax for non-residents: taxable assets and the €1.3 million threshold
- French Overseas Social Security Fund: Membership Conditions
Official sources
- BOFiP, BOI-INT-CVB-RUS, France-Russia convention (version of 23/10/2024): https://bofip.impots.gouv.fr/bofip/2454-PGP.html
- BOFiP, BOI-ANNX-000306, list of tax treaties (29/04/2026): https://bofip.impots.gouv.fr/bofip/2509-PGP.html/identifiant=BOI-ANNX-000306-20260429
- BOFiP, BOI-IR-CHAMP-10, tax domicile: https://bofip.impots.gouv.fr/bofip/1911-PGP.html/identifiant=BOI-IR-CHAMP-10-20160728
- impots.gouv.fr, France-Russia convention, consolidated text: https://www.impots.gouv.fr/sites/default/files/media/10_conventions/russie/convention_russie_cml.pdf
- National Assembly, annex to the 2027 Finance Bill, France's network for intelligence sharing: https://www.assemblee-nationale.fr/dyn/contenu/visualisation/1129774/file/19-Jaune%202027%20-%20R%C3%A9seau%20de%20la%20France%20en%20mati%C3%A8re%20d%27%C3%A9change%20de%20renseignement.pdf
- French Treasury Directorate General, Russia sanctions (published on 19/03/2026): https://www.tresor.economie.gouv.fr/services-aux-entreprises/sanctions-economiques/russie-en-lien-avec-la-violation-par-la-russie-de-la-souverainete-et-de-l-integrite-territoriale-de-l-ukraine
- Cleiss, social protection in Russia (2025): https://www.cleiss.fr/docs/regimes/regime_russie.html
- diplomatie.gouv.fr, Travel advice, Russia: https://www.diplomatie.gouv.fr/fr/conseils-aux-voyageurs/conseils-par-pays-destination/russie/
- diplomatie.gouv.fr, Russia fact sheet (PDF version): https://www.diplomatie.gouv.fr/files/files/pdf/cav/Russie%20-%20Minist%C3%A8re%20de%20l’Europe%20et%20des%20Affaires%20%C3%A9trang%C3%A8res.pdf