French Withholding Tax Guide for International Royalty Payments
French Withholding Tax Guide for International Royalty Payments
This page provides a complete educational overview of how French withholding tax applies to royalty payments made to foreign rights holders. It is designed for non-experts as well as advanced users and aims to simplify a complex regulatory environment through clear explanations and structured guidance.
The reference table should be inserted after Section 3, once the user clearly understands the meaning and purpose of each column. See the integration instructions below.
Purpose of This Guide
The goal of this guide is to explain, in practical terms, how French withholding tax works when royalties are paid to rights holders located outside France. Because the applicable rate depends on multiple factors such as tax treaties, domestic rules, suspended agreements, or NCST classifications, users need a reliable reference tool.
This page defines these concepts clearly and presents a jurisdiction-by-jurisdiction table that consolidates all relevant information. Once the concepts are understood, the table becomes an operational decision tool.
How Withholding Tax Is Determined
Every royalty payment you issue must follow a three-step evaluation:
- Identify the tax residency of the rights holder.
- Check the treaty status between France and that jurisdiction.
- Apply the correct withholding rate according to domestic law, treaty provisions, or NCST treatment.
When applicable, the correct treaty rate can only be applied if all mandatory documents are provided, certified, and valid.
Explanation of the Table Columns
This section prepares the reader to correctly interpret the table. The table should be placed immediately after this section.
Jurisdiction
The country or territory in which the rights holder is tax-resident. This determines which treaty rules or domestic rules apply.
Treaty Status
Indicates the nature of the relationship between France and the jurisdiction. Five different statuses exist:
- Tax Treaty in Force
- No Tax Treaty
- Treaty Suspended
- NCST (Non-Cooperative States and Territories)
- French Domestic Law
Each status is explained in detail in Section 4.
Applicable Rate
The withholding rate to apply to French-sourced royalties for that jurisdiction. The rate depends on treaty status, NCST classification, or domestic rules.
Mandatory Documents
Lists the certificates required to benefit from a reduced treaty rate. If these documents are missing or incomplete, you must apply the domestic default rate.
BOFiP Reference
When available, this is the direct citation of the French tax authority’s official commentary.
| Jurisdiction | Treaty Status | Applicable Rate | Mandatory Documents | BOFiP Reference |
|---|---|---|---|---|
| Afghanistan | No Tax Treaty | 25% | ||
| Åland Islands (Finland) | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-FIN |
| Albania | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ALB |
| Algeria | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-DZA |
| American Samoa (United States) | NCST (No Tax Treaty) | 75% | ||
| Andorra | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-AND |
| Angola | No Tax Treaty | 25% | ||
| Anguilla (United Kingdom) | No Tax Treaty | 25% | ||
| Antigua and Barbuda | NCST (No Tax Treaty) | 75% | ||
| Argentina | Tax Treaty in Force | 18% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ARG |
| Armenia | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ARM |
| Aruba (Netherlands) | No Tax Treaty | 25% | ||
| Australia | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-AUS |
| Austria | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-AUT |
| Azerbaijan | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-AZE |
| Bahamas | No Tax Treaty | 25% | ||
| Bahrain | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BHR |
| Bangladesh | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BGD |
| Barbados | No Tax Treaty | 25% | ||
| Belarus | Treaty Suspended | 25% | BOI-INT-CVB-BLR | |
| Belgium | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BEL |
| Belize | No Tax Treaty | 25% | ||
| Benin | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BEN |
| Bermuda (United Kingdom) | No Tax Treaty | 25% | ||
| Bhutan | No Tax Treaty | 25% | ||
| Bolivia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BOL |
| Bonaire (Netherlands) | No Tax Treaty | 25% | ||
| Bosnia and Herzegovina | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BIH |
| Botswana | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BWA |
| Brazil | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BRA |
| British Indian Ocean Territory (United Kingdom) | No Tax Treaty | 25% | ||
| British Virgin Islands (United Kingdom) | No Tax Treaty | 25% | ||
| Brunei | No Tax Treaty | 25% | ||
| Bulgaria | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BGR |
| Burkina Faso | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-BFA |
| Burundi | No Tax Treaty | 25% | ||
| Cambodia | No Tax Treaty | 25% | ||
| Cameroon | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CMR |
| Canada | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CAN |
| Cape Verde | No Tax Treaty | 25% | ||
| Cayman Islands | No Tax Treaty | 25% | ||
| Central African Republic | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CAF |
| Chad | No Tax Treaty | 25% | ||
| Chile | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CHL |
| China | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CHN |
| Colombia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-COL |
| Comoros | No Tax Treaty | 25% | ||
| Congo (Republic of) | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-COG |
| Cook Islands (New Zealand) | No Tax Treaty | 25% | ||
| Costa Rica | No Tax Treaty | 25% | ||
| Croatia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-HRV |
| Cuba | No Tax Treaty | 25% | ||
| Curaçao (Netherlands) | No Tax Treaty | 25% | ||
| Cyprus | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CYP |
| Czech Republic | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CZE |
| Denmark | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-DNK |
| Djibouti | No Tax Treaty | 25% | ||
| Dominica | No Tax Treaty | 25% | ||
| Dominican Republic | No Tax Treaty | 25% | ||
| Ecuador | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ECU |
| Egypt | Tax Treaty in Force | 12% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-EGY |
| El Salvador | No Tax Treaty | 25% | ||
| Equatorial Guinea | No Tax Treaty | 25% | ||
| Eritrea | No Tax Treaty | 25% | ||
| Estonia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-EST |
| Eswatini | No Tax Treaty | 25% | ||
| Ethiopia | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ETH |
| Falkland Islands (United Kingdom) | No Tax Treaty | 25% | ||
| Faroe Islands (Denmark) | No Tax Treaty | 25% | ||
| Fiji | NCST (No Tax Treaty) | 75% | ||
| Finland | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-FIN |
| French Guiana (France) | French Domestic Law | 0% | BOI-INT-CVB-FRA | |
| French Polynesia (France) | French Domestic Law | 0% | BOI-INT-CVB-PYF | |
| Gabon | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-GAB |
| Gambia | No Tax Treaty | 25% | ||
| Georgia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-GEO |
| Germany | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-DEU |
| Ghana | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-GHA |
| Gibraltar (United Kingdom) | No Tax Treaty | 25% | ||
| Greece | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-GRC |
| Grenada | No Tax Treaty | 25% | ||
| Guatemala | No Tax Treaty | 25% | ||
| Guernsey (United Kingdom) | No Tax Treaty | 25% | ||
| Guinea | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-GIN |
| Guinea-Bissau | No Tax Treaty | 25% | ||
| Guyana | No Tax Treaty | 25% | ||
| Haiti | No Tax Treaty | 25% | ||
| Honduras | No Tax Treaty | 25% | ||
| Hong Kong | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-HKG |
| Hungary | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-HUN |
| Iceland | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ISL |
| India | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-IND |
| Indonesia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-IDN |
| Iran | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-IRN |
| Iraq | No Tax Treaty | 25% | ||
| Ireland | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-IRL |
| Isle of Man (United Kingdom) | No Tax Treaty | 25% | ||
| Israel | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ISR |
| Italy | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ITA |
| Ivory Coast (Côte d’Ivoire) | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CIV |
| Jamaica | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-JAM |
| Japan | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-JPN |
| Jersey (United Kingdom) | No Tax Treaty | 25% | ||
| Jordan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-JOR |
| Kazakhstan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-KAZ |
| Kenya | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-KEN |
| Kiribati | No Tax Treaty | 25% | ||
| Korea, Republic of (South Korea) | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-KOR |
| Kosovo | No Tax Treaty | 25% | ||
| Kuwait | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-KWT |
| Kyrgyzstan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-KGZ |
| Laos | No Tax Treaty | 25% | ||
| Latvia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LVA |
| Lebanon | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LBN |
| Lesotho | No Tax Treaty | 25% | ||
| Liberia | No Tax Treaty | 25% | ||
| Libya | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LBY |
| Liechtenstein | No Tax Treaty | 25% | ||
| Lithuania | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LTU |
| Luxembourg | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LUX |
| Macao (China) | No Tax Treaty | 25% | ||
| Madagascar | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MDG |
| Malawi | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MWI |
| Malaysia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MYS |
| Maldives | No Tax Treaty | 25% | ||
| Mali | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MLI |
| Malta | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MLT |
| Marshall Islands | No Tax Treaty | 25% | ||
| Mauritania | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MRT |
| Mauritius | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MUS |
| Mayotte (France) | French Domestic Law | 0% | BOI-INT-CVB-FRA | |
| Mexico | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MEX |
| Micronesia | No Tax Treaty | 25% | ||
| Moldova | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MDA |
| Monaco | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MCO |
| Mongolia | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MNG |
| Montenegro | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MNE |
| Montserrat (United Kingdom) | No Tax Treaty | 25% | ||
| Morocco | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MAR |
| Mozambique | No Tax Treaty | 25% | ||
| Myanmar | No Tax Treaty | 25% | ||
| Namibia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-NAM |
| Norfolk Island (Australia) | No Tax Treaty | 25% | ||
| North Korea | No Tax Treaty | 25% | ||
| North Macedonia | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-MKD |
| Northern Mariana Islands (United States) | No Tax Treaty | 25% | ||
| Norway | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-NOR |
| Oman | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-OMN |
| Pakistan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-PAK |
| Palau | NCST (No Tax Treaty) | 75% | ||
| Palestine | No Tax Treaty | 25% | ||
| Panama | NCST (No Tax Treaty) | 75% | BOI-INT-CVB-PAN | |
| Papua New Guinea | No Tax Treaty | 25% | ||
| Paraguay | No Tax Treaty | 25% | ||
| Peru | No Tax Treaty | 25% | ||
| Philippines | Tax Treaty in Force | 15% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-PHL |
| Pitcairn Islands (United Kingdom) | No Tax Treaty | 25% | ||
| Poland | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-POL |
| Portugal | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-PRT |
| Puerto Rico (United States) | No Tax Treaty | 25% | ||
| Qatar | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-QAT |
| Quebec (Canada) | Tax Treaty in Force | 0% | Certified Form 5000 (by Revenu Québec) + Form 5003 | BOI-INT-CVB-CA-QC |
| Réunion (France) | French Domestic Law | 0% | BOI-INT-CVB-REU | |
| Romania | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ROU |
| Russia | Treaty Suspended (NCST) | 75% | BOI-INT-CVB-RUS | |
| Rwanda | No Tax Treaty | 25% | ||
| Saint Barthélemy (France) | French Domestic Law | 0% | BOI-INT-CVB-BL | |
| Saint Kitts and Nevis | No Tax Treaty | 25% | ||
| Saint Lucia | No Tax Treaty | 25% | ||
| Saint Martin (France) | French Domestic Law | 0% | BOI-INT-CVB-MAF | |
| Saint Pierre and Miquelon (France) | French Domestic Law | 0% | BOI-INT-CVB-SPM | |
| Saint Vincent & the Grenadines | No Tax Treaty | 25% | ||
| Samoa | NCST (No Tax Treaty) | 75% | ||
| San Marino | No Tax Treaty | 25% | ||
| Sao Tome and Principe | No Tax Treaty | 25% | ||
| Saudi Arabia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SAU |
| Senegal | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SEN |
| Serbia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SRB |
| Seychelles | No Tax Treaty | 25% | ||
| Sierra Leone | No Tax Treaty | 25% | ||
| Singapore | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SGP |
| Sint Maarten (Netherlands) | No Tax Treaty | 25% | ||
| Slovakia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SVK |
| Slovenia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SVN |
| Solomon Islands | No Tax Treaty | 25% | ||
| Somalia | No Tax Treaty | 25% | ||
| South Africa | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ZAF |
| South Sudan | No Tax Treaty | 25% | ||
| Spain | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ESP |
| Sri Lanka | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-LKA |
| Sudan | No Tax Treaty | 25% | ||
| Suriname | No Tax Treaty | 25% | ||
| Svalbard and Jan Mayen (Norway) | No Tax Treaty | 25% | ||
| Sweden | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SWE |
| Switzerland | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-CHE |
| Syria | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-SYR |
| Taiwan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-TWN |
| Tajikistan | No Tax Treaty | 25% | ||
| Tanzania | No Tax Treaty | 25% | ||
| Thailand | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-THA |
| Timor-Leste | No Tax Treaty | 25% | ||
| Togo | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-TGO |
| Tokelau (New Zealand) | No Tax Treaty | 25% | ||
| Tonga | No Tax Treaty | 25% | ||
| Trinidad and Tobago | NCST (No Tax Treaty) | 75% | BOI-INT-CVB-TTO | |
| Tunisia | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-TUN |
| Turkey | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-TUR |
| Turkmenistan | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-TKM |
| Turks and Caicos Islands (United Kingdom) | NCST (No Tax Treaty) | 75% | ||
| Tuvalu | No Tax Treaty | 25% | ||
| Uganda | No Tax Treaty | 25% | ||
| Ukraine | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-UKR |
| United Arab Emirates | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ARE |
| United Kingdom | Tax Treaty in Force | 0% | Certified Form 5000 (by HMRC) + Form 5003 | BOI-INT-CVB-GBR |
| United States | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 + IRS Form 6166 | BOI-INT-CVB-USA |
| Uruguay | No Tax Treaty | 25% | ||
| Uzbekistan | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-UZB |
| Vanuatu | NCST (No Tax Treaty) | 75% | ||
| Vatican City | No Tax Treaty | 25% | ||
| Venezuela | Tax Treaty in Force | 5% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-VEN |
| Vietnam | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-VNM |
| Wallis and Futuna (France) | French Domestic Law | 0% | BOI-INT-CVB-WLF | |
| Western Sahara | No Tax Treaty | 25% | ||
| Yemen | No Tax Treaty | 25% | ||
| Zambia | Tax Treaty in Force | 0% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ZMB |
| Zimbabwe | Tax Treaty in Force | 10% | Certified Form 5000 + Form 5003 | BOI-INT-CVB-ZWE |
Understanding Treaty Status Categories
Tax Treaty in Force
A bilateral treaty exists and is fully active. A reduced rate may apply if all required documents are supplied and certified.
No Tax Treaty
No treaty exists. Domestic French rates apply without exception.
Treaty Suspended
A treaty exists but is officially suspended. It cannot be used to apply reduced rates.
NCST (Non-Cooperative States and Territories)
Jurisdictions considered non-cooperative under French tax law. A punitive rate of 75% applies.
French Domestic Law
Applicable to French overseas departments and territories. No withholding applies.
Mandatory Documents Explained
This section gives clear, educational explanations for each document:
Certified Form 5000
Attests tax residency. Must be certified by the foreign tax authority.
Form 5003
Provides complementary information required by French authorities for treaty application.
IRS Form 6166 (United States)
A mandatory US residency certificate issued by the IRS.
Revenu Québec Certification (Quebec)
Form 5000 must be certified by Revenu Québec.
HMRC Certification (United Kingdom)
Form 5000 must be certified by HMRC to qualify for the 0 percent rate.
Best Practices for Global Withholding Compliance
• Always request certified forms, never copies or unsigned versions. • Track expiry dates rigorously. • Apply domestic rates when documents are missing. • Apply NCST sanctions immediately when applicable. • Keep documented proof of all compliance steps.
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- Updates and Limitations
This guide reflects the current regulatory environment. Treaty statuses, NCST lists, and BOFiP references may evolve. Regular updates are required.
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