Treaty detail
France - Japan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1995-03-03
Effective
1996-03-24
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 0%
The 2007 protocol provides zero treatment for qualifying corporate shareholders with substantial direct ownership. Portfolio dividends face the 10 percent ceiling.
Interest
Rate: 10%
The 10 percent ceiling can be reduced to zero for qualifying financial-institution and government interest under the article as amended.
Royalties
Rate: 0%
The treaty eliminates source-country royalty withholding under the article as amended.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the treaty wording as amended by the 2007 protocol.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1995 wording as amended by the 2007 protocol.
Article 4 has been refined by the 2007 protocol to align with modern OECD principles.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The treaty uses the standard 12-month construction-site threshold as amended.
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.
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 2007 protocol.
Article 11
Interest
Limits source-country withholding on qualifying interest with carve-outs.
Article 11 produces a 10 percent ceiling but allows zero treatment for qualifying financial-institution and government interest.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding under the article as amended.
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–FR treaty
- TreatyUS–JP treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyCA–FR treaty
- TreatyCA–JP treaty
- TreatyAU–JP treaty
- TreatyDE–FR treaty
Primary sources
- impots.gouv.fr internationalVerified 2026-05-20
- Japan MOF: tax conventionsVerified 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.