🇬🇧 United Kingdom — 🇫🇷 France

Tax Treaty / Double Tax Avoidance Agreement detail

The UK-France Double Taxation Convention was signed on 19 June 2008 and entered into force on 18 December 2009, replacing a 1968 convention. As two of Europe's largest economies with deep financial, cultural, and expatriate ties, this treaty is among the most consequential bilateral tax agreements in Europe. Dividends paid by a French company to a UK company owning at least 10% are exempt from French withholding. Qualifying pension funds similarly receive full exemption. A 5% rate applies to direct investments below that threshold but above minimal holdings, and 15% applies to portfolio dividends. Interest payments are fully exempt from withholding in both directions. Royalties are similarly exempt, facilitating cross-border licensing of trademarks, patents, and software. The treaty includes standard OECD Model permanent establishment rules and specific provisions for real estate investment trusts and equivalent French structures (SIIs and SCPIs). France's Prélèvements Sociaux—social levies charged on investment income of French residents—are not covered by the treaty, though their applicability to non-resident UK nationals has been a matter of EU Court of Justice jurisprudence (now a domestic French matter post-Brexit). Post-Brexit, the treaty operates entirely independently of EU directives. French and UK competent authorities have exchanged letters to clarify the continued applicability of the treaty to post-Brexit UK structures. The residency tie-breaking cascade follows the OECD model. A post-Brexit bilateral social security arrangement preserves rights for cross-border workers comparable to those enjoyed under EU free movement.