Treaty detail
France - Netherlands tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1973-03-16
Effective
1974-03-29
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct-ownership thresholds under the treaty. EU Parent-Subsidiary Directive provides parallel zero treatment in qualifying intra-EU fact patterns.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government and central-bank interest. EU Interest and Royalties Directive may provide parallel relief.
Royalties
Rate: 0%
The treaty generally eliminates source-country royalty withholding under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows older treaty wording.
Other treaty flags
Pension treatment is article-specific.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1973 wording.
Article 4 reflects the 1973 wording. Both countries have refined their domestic residence rules since, which affects how the article is applied in practice.
Article 5
Permanent Establishment
Sets the business-presence threshold under older OECD-aligned wording.
The treaty uses an older construction-site threshold consistent with 1970s-era OECD practice.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 reflects pre-OECD-authorised-approach principles.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 15 percent and 5 percent treaty ceilings. EU Parent-Subsidiary Directive provides parallel relief in qualifying cases.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 produces a 10 percent ceiling. EU Interest and Royalties Directive may provide parallel zero treatment in qualifying cases.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding under the article.
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–NL treaty
- TreatyGB–FR treaty
- TreatyGB–NL treaty
- TreatyCA–FR treaty
- TreatyDE–FR treaty
- TreatyDE–NL treaty
- TreatyCH–FR treaty
Primary sources
- impots.gouv.fr internationalVerified 2026-05-20
- Netherlands government: tax treatiesVerified 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.