France’s Treaty Network
France maintains one of the world’s most extensive treaty networks: 120+ double tax treaties, 100+ bilateral investment treaties, and trade agreements through the EU. This infrastructure underpins France’s position as Europe’s #1 FDI destination.
Key Double Tax Treaties
| Country | Treaty Year | Key Provisions |
|---|---|---|
| United States | 1994 (amended 2009) | Withholding: 15% dividends, 0% interest, 0% royalties |
| United Kingdom | 2008 | Withholding: 15% dividends, 0% interest, 0% royalties |
| Switzerland | 1966 (amended 2014) | Cross-border worker provisions, pension taxation |
| Germany | 1959 (amended 2015) | Franco-German integration provisions |
| UAE | 1989 | 0% UAE tax; France taxes under domestic law |
| Singapore | 2015 | Modern provisions, IP-friendly |
| China | 2013 | 10% dividends, 10% interest, 10% royalties |
Investment Protection
France’s bilateral investment treaties (BITs) guarantee: fair and equitable treatment, protection against expropriation, free transfer of investment returns, and access to international arbitration (ICSID). This framework reduces political risk for investors operating through French structures.
EU Trade Agreements (via France)
As an EU member state, France benefits from the bloc’s comprehensive trade agreement network. Key agreements affecting French business: EU-Canada (CETA) — eliminated 98% of tariffs, mutual recognition of professional qualifications; EU-Japan (EPA) — world’s largest bilateral trade zone, critical for French luxury goods and agriculture; EU-Vietnam (EVFTA) — fastest-growing ASEAN market; EU-UK Trade and Cooperation Agreement — post-Brexit framework governing the Channel relationship. Pending agreements with Mercosur, Australia, and India could further expand market access for French companies.
Bilateral Investment Treaty Network
France has signed 100+ bilateral investment treaties (BITs) providing investment protection in developing and emerging markets. These treaties guarantee: fair and equitable treatment (FET), protection against expropriation without compensation, free transfer of capital and returns, most-favored-nation treatment (MFN), and access to international arbitration through ICSID (World Bank) or UNCITRAL. For investors using France as a gateway to Africa and the Middle East, these treaties provide critical legal protection that reduces political and regulatory risk.
Social Security Agreements
France has signed bilateral social security agreements with 40+ countries, preventing double social contributions and protecting pension rights for mobile workers. Key agreements cover the United States (totalization agreement since 1987), Canada, Japan, South Korea, India, Brazil, and all EEA/Swiss states (via EU regulations). For executives relocating through the Talent Passport, understanding these agreements is essential for optimizing social charge obligations and preserving pension entitlements accumulated in previous countries of residence.