Treaty detail
Germany - France tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1959-07-21
Effective
1961-10-04
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The 2015 protocol provides for a zero rate for qualifying corporate shareholders with substantial direct ownership. EU Parent-Subsidiary Directive provides parallel relief in qualifying intra-EU fact patterns.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest.
Royalties
Rate: 0%
The treaty eliminates source-country royalty withholding across the major categories.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the OECD model wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension, government-service, and frontier-worker provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1959 wording as amended by multiple protocols.
Article 4 has been refined by multiple protocols. The 2015 protocol updated certain residence and anti-abuse provisions.
Article 5
Permanent Establishment
Sets the business-presence threshold with construction and service rules.
The treaty uses a 12-month construction-site threshold as amended by protocol. Cross-border worker rules are particularly relevant given the Franco-German border.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 has been refined by protocol to align with OECD-aligned profit-attribution principles.
Article 10
Dividends
Caps source-country dividend withholding with a zero rate for qualifying substantial shareholders.
Article 10 provides zero treatment for qualifying corporate shareholders meeting the substantial-direct-ownership threshold under the 2015 protocol. EU Parent-Subsidiary Directive provides parallel relief in qualifying cases.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding. The EU Interest and Royalties Directive provides parallel relief in qualifying cases.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding across the major categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
- TreatyDE–NL treaty
- TreatyCH–DE treaty
Primary sources
- BMF: DoppelbesteuerungsabkommenVerified 2026-05-20
- impots.gouv.fr internationalVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.