Treaty detail
Switzerland - France tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1966-09-09
Effective
1967-08-26
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The treaty as amended provides zero treatment for qualifying corporate shareholders with substantial direct ownership.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest.
Royalties
Rate: 5%
Royalties generally face a 5 percent ceiling under the treaty.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the treaty wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed frontier-worker provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1966 wording as amended by protocols.
Article 4 has been refined by multiple protocols, including the 2009 protocol addressing information exchange.
Article 5
Permanent Establishment
Sets the business-presence threshold including frontier-worker rules.
The treaty includes specific provisions on cross-border workers given the long shared Franco-Swiss 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.
Article 10
Dividends
Caps source-country dividend withholding with a zero rate for qualifying substantial shareholders.
Article 10 produces a zero rate for qualifying corporate shareholders with substantial direct ownership.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding on qualifying interest.
Article 12
Royalties
Caps royalties at a 5 percent ceiling.
Article 12 limits source-country royalty withholding to 5 percent across the core 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–FR treaty
- TreatyUS–CH treaty
- TreatyGB–FR treaty
- TreatyGB–CH treaty
- TreatyCA–FR treaty
- TreatyDE–FR treaty
- TreatyCH–DE treaty
- TreatyFR–NL treaty
Primary sources
- impots.gouv.fr internationalVerified 2026-05-20
- Swiss Federal Tax Administration treaty pageVerified 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.