Treaty detail
United States - France tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1994-08-31
Effective
1996-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The 5 percent corporate rate generally depends on direct ownership and treaty qualification. Certain protocol-based exceptions and anti-abuse rules still require article-level review.
Interest
Rate: 0%
The treaty table shows a general zero-percent result, but beneficial ownership, article scope, and protocol updates still matter.
Royalties
Rate: 0%
The treaty generally eliminates withholding on royalties, including the core copyright, patent, and know-how categories summarized in IRS Treaty Table 1.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis remains important where a person habitually concludes contracts or habitually secures orders on behalf of the enterprise under the treaty wording.
Other treaty flags
Pension treatment is article-specific. IRS treaty tables show that some U.S.-source pension payments can still face source-country withholding, so pension questions should not be reduced to the general dividend-interest-royalty snapshot.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the starting point for any claim to reduced withholding or treaty protection.
The residence article is especially important for dual-country fact patterns and for any claim that depends on being a resident of France or the United States for treaty purposes rather than just domestic-law residence.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
For France, Article 5 includes a classic construction and installation rule: a building site, construction or installation project, drilling rig, or ship becomes a permanent establishment only if it lasts more than twelve months.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
This is the operating rule founders and consultants usually care about after the PE analysis. It is the article that keeps business profits from being taxed in the other state when the PE threshold has not been crossed.
Article 10
Dividends
Provides treaty limits on source-country dividend withholding in qualifying cases.
The dividend article matters for closely held companies, holding-company structures, and founder distributions. The treaty table's 15 percent and 5 percent rates are the quick snapshot, but the full article and protocols control the outcome.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Interest is one of the clearest areas where the treaty can materially change the domestic-law withholding result, but the practical analysis still depends on documentation and beneficial ownership.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article is especially valuable for software, licensing, and IP structures because the treaty table shows a broad zero-percent result across the major royalty 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–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
- TreatyUS–IN treaty
Primary sources
- France treaty documents pageVerified 2026-05-04
- Official U.S.-France treaty PDFVerified 2026-05-04
- IRS Tax Treaty Table 1Verified 2026-05-04
- France technical explanationVerified 2026-05-04
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.