🇫🇷 Tax Treaty
Cyprus–France Double Tax Treaty
The Cyprus-France DTA provides 0% royalty withholding and reduced dividend rates, suitable for IP and holding structures involving French operations — with genuine substance required to withstand French anti-abuse scrutiny.
Withholding Tax Rates at a Glance
(reduced rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 15% | Standard WHT rate |
| Dividends (reduced) | 10% | companies holding ≥25% of payer capital |
| Interest | 10% | On interest payments between the countries |
| Royalties | 0% | On royalties, licences, and IP income |
| Capital Gains (Cyprus side) | 0% | 0% in Cyprus; French domestic CGT may apply on French property |
Treaty signed: 1981. In force: 1983. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ 0% withholding on royalties from France
- ✓ 10% withholding on dividends for qualifying holdings (vs French domestic 12.8–30%)
- ✓ 10% on interest
Common Cyprus–France Structures
- → Cyprus IP company holding patents licensed to French entities
- → Cyprus holding company for French investments
Planning Notes
France has strong domestic anti-abuse rules and regularly challenges treaty shopping. Cyprus companies receiving French income require genuine substance to rely on treaty protection.
Dual Residency Tiebreaker
Place of effective management
Planning a Cyprus–France structure?
Treaty rates are only part of the picture. We help you design and implement Cyprus company structures that take full advantage of the Cyprus–France double tax treaty — with genuine substance and robust documentation.