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Disclaimer

Reprtoir provides documentation exclusively from the perspective of the French tax administration. This page does not constitute legal or tax advice. Reprtoir cannot validate a beneficiary’s tax residency, cannot advise on foreign administrative procedures, and cannot interpret the tax rules of other countries. Beneficiaries must confirm all requirements directly with their accountant or their local tax authority.

Overview

This page explains how international withholding tax applies to royalty payments generated through Reprtoir’s Delivery System. The objective is to provide a clear overview of how cross-border withholding tax works, why it exists, and how it affects both companies and individuals who receive royalties from France.

International withholding tax is not a French peculiarity. It is a standard mechanism used worldwide to ensure that income paid across borders is properly taxed. Almost every country applies some form of withholding when royalties are paid to a foreign beneficiary. France follows the same international principles.

In this context, France is considered the source country for royalties processed through Reprtoir. French tax law requires Reprtoir to apply a withholding tax whenever royalties are paid to a foreign beneficiary.

General Principles

When royalties are paid by a source country to a beneficiary located in another country, most tax systems impose withholding tax. The payer must withhold a portion of the payment before transferring the funds to the beneficiary. Withholding rates vary depending on:

• the domestic law of the source country
• the existence of a tax treaty between the two countries
• the documentation provided by the beneficiary

France applies these principles to royalties paid through Reprtoir.

• If no tax residency documentation is provided, France applies a statutory withholding rate of 25 percent.
• If a tax treaty exists, a reduced rate may apply, sometimes down to zero.
• If the country is classified as NCST (Non-Cooperative State or Territory) or if a treaty is suspended, France applies a 75 percent withholding rate.

Reprtoir does not choose the rate. The rate is determined by the French tax administration based solely on the beneficiary’s country of residence and the documents provided.

These rules apply equally to companies and individuals.

Required Documentation

To apply a reduced withholding rate under a tax treaty, the French tax administration requires certified documentation proving the beneficiary’s tax residency.

For most jurisdictions, two documents are mandatory:

• “Form 5000” (Certificate of Residence)
• “Form 5003” (Withholding Tax Reduction or Refund Request)

For U.S. tax residents, one additional document is required:

• “IRS Form 6166” (Residency Certificate issued by the IRS)

Without these documents, Reprtoir is legally required to withhold at the domestic statutory rate or at the NCST rate.

How Reprtoir Applies Withholding Tax

Reprtoir applies withholding tax automatically based on:

• the default French statutory rate (25 percent)
• the tax treaty rate when certified documentation is provided
• the NCST rate (75 percent) for non-cooperative jurisdictions or suspended treaties

Reprtoir never applies a reduced rate until all required documents have been received, checked, and validated.

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Important Operational Notice

Do not invoice Reprtoir while your tax residency documentation is still being processed, or if you have submitted your forms but have not yet received explicit confirmation from Reprtoir that they are valid and sufficient to apply the treaty rate. If you invoice before confirmation and Reprtoir must apply the default withholding rate, you are solely responsible for requesting a refund directly from the French tax administration. Reprtoir cannot intervene or recover the amounts on your behalf.