Treaty detail
United Kingdom - France tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2008-06-19
Effective
2009-12-18
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The treaty provides a 0 percent rate for qualifying corporate shareholders with a substantial direct shareholding under the article. The general 15 percent rate applies otherwise. EU Parent-Subsidiary Directive remains relevant in qualifying intra-EU fact patterns despite post-Brexit nuances.
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 under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the OECD model with habitual-conclusion wording.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension and government-service articles.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned rules.
Article 4 follows the modern OECD model and resolves dual-resident entity cases through mutual agreement procedure rather than effective-management determination.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The 2008 treaty uses the standard 12-month construction threshold. Dependent-agent rules follow the OECD model wording.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 aligns with the OECD's authorised-approach to profit attribution.
Article 10
Dividends
Caps source-country withholding on dividends, with a zero rate for qualifying substantial shareholders.
Article 10 provides a zero rate for qualifying corporate shareholders meeting the substantial-direct-ownership threshold. The general 15 percent rate applies otherwise.
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 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–GB treaty
- TreatyUS–FR treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC: France tax treatiesVerified 2026-05-20
- France: 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.