International Tax 2026 Comparisons

Domestic Legislation

The principal source of French international tax law is the Code général des impôts (General Tax Code; CGI), supplemented by its regulatory annexes and the Livre des procédures fiscales (Book of Tax Procedures; LPF). Key provisions address tax residence, non-resident taxation, the corporate territorial principle, transfer pricing and anti-avoidance rules.

The definition of a resident in domestic French law is found in Article 4 B of the CGI.

Administrative Guidance

The Bulletin Officiel des Finances Publiques (Official Bulletin of Public Finances; BOFiP) provides a binding administrative doctrine that taxpayers may rely upon. This includes specific guidance on treaty interpretation and international reporting obligations. The BOFiP is binding on the tax authorities.

Case Law

The French Supreme Court (Conseil d’État) plays a decisive role through rulings on treaty interpretation, beneficial ownership and anti-abuse provisions. It often relies on the OECD Model Commentary as a supplementary interpretative tool.

Treaty Network

France has over 120 bilateral tax conventions in force, generally following the OECD Model Convention. The treaty network covers all major trading partners and typically addresses elimination of double taxation, allocation of taxing rights and exchange of information.

Constitutional Framework

Under Article 55 of the Constitution, duly ratified tax treaties hold supra-legislative rank, prevailing over conflicting domestic legislation. This principle has been consistently upheld since the Supreme Court’s Nicolo decision (1989).

Hierarchy

The hierarchy of sources is as follows:

• constitutional provisions sit at the apex;
• EU law enjoys primacy over national law;
• tax treaties rank below EU law but above domestic statutes;
• domestic legislation applies to the extent that it does not conflict with treaties; and
• administrative doctrine (BOFiP) binds the tax authorities but not the courts.

Practical Implications

In practice, the Administrative Courts first apply domestic French law and then check whether a treaty provision prevents or limits the application of domestic law.

In France, the principle is that a treaty can only reduce the taxation power of the contracting state, and cannot create a new right to tax that is not provided by domestic law.

Taxpayers frequently invoke treaty provisions to override less favourable domestic rules, particularly to reduce withholding tax rates on cross-border payments. Courts apply the Vienna Convention on the Law of Treaties principles and may depart from administrative doctrine where it conflicts with the treaty text.

General Alignment

France’s treaty practice is firmly rooted in the OECD Model Convention, reflecting its role as a founding OECD member. Most French treaties closely follow the OECD Model structure in their allocation of taxing rights and dispute resolution mechanisms.

Key Deviations

Notable deviations from the OECD Model include:

• a broader definition of royalties that often includes payments for industrial, commercial or scientific equipment;
• reliance on the credit method rather than the exemption method for double taxation elimination, with exceptions (notably the exemption method used with Germany); and
• in treaties with developing countries, elements drawn from the UN Model such as limited source-state taxation on technical service fees.

France has entered reservations on several OECD Model Commentary articles, particularly regarding the treatment of partnerships and beneficial ownership interpretation.

France signed the Multilateral Instrument (MLI) on 7 June 2017 and ratified it on 26 September 2018, with its entry into force on 1 January 2019. France adopted a broad approach, listing a substantial number of bilateral treaties as Covered Tax Agreements.

France opted for the Principal Purpose Test (PPT) as the minimum standard for treaty abuse prevention, and chose to apply mandatory binding arbitration under Part VI. The MLI has effectively modified a significant portion of France’s bilateral treaty network, introducing anti-abuse provisions, updated permanent establishment rules, and improved dispute resolution mechanisms.

Individual Taxation

France taxes resident individuals on their worldwide income. Non-residents are taxed only on French-source income as defined by the CGI. This worldwide approach means that residents must report and pay tax on income earned anywhere in the world, subject to double taxation relief.

Corporate Taxation

For companies, France applies a territorial principle: entities are taxed only on profits derived from activities carried on in France or attributable to a French permanent establishment. Foreign branch and subsidiary profits are generally excluded, with limited exceptions such as controlled foreign company (CFC) rules.

Overseas Territories

France’s overseas departments generally follow metropolitan tax legislation with specific incentives. Overseas collectives such as New Caledonia have autonomous tax systems and are treated as separate jurisdictions for treaty purposes.

Domestic Criteria

The CGI provides four alternative criteria, any one of which can establish French tax residence:

• where the taxpayer’s home (foyer) is in France, meaning where the family habitually lives;
• if the taxpayer has no home (in France or abroad), they can be deemed resident if they have their principal place of abode in France (ie, the country where they spend the most time in a year);
• where they exercise a professional activity in France, unless that activity is ancillary (tax authorities consider that being a director of a French company is presumed to be a professional activity in France); or
• where the centre of their economic interests is located in France, being defined as the place from where the taxpayer derives the majority of their revenues.

Treaty Tie-Breaker Rules

Where a bilateral tax treaty applies, the treaty’s tie-breaker rules prevail over domestic criteria. The Conseil d’État has developed extensive case law clarifying these domestic criteria, particularly the concept of “foyer” in cross-border family situations.

Since 2025, where a taxpayer is deemed to be non-resident by a treaty provision, they will also be considered non-resident for domestic law purposes.

Progressive Income Tax

Residents are subject to progressive income tax at rates ranging from 0% to 45% on worldwide income, plus a high-income surtax of 3% to 4% above EUR250,000.

France taxes income by category: employment, business, real estate, investment income and capital gains.

In general, revenues from a professional activity (employment, business profits of an individual, retirement pensions, etc) would be subject to the progressive income tax.

In contrast, revenues from financial investments (capital gains, dividends, interest) would generally be subject to a flat tax of 12.8%, except where the taxpayer elects to have them taxed at the progressive tax rate.

Rental income is generally subject to the income tax rate, and real estate capital gains are subject to a specific tax rate of 19%, which can be reduced with an allowance for length of ownership.

Social Contributions

France applies specific levies to the different types of social contributions.

Contributions on the revenue from a professional activity are levied by the social authorities (URSSAF) and range from approximately 22% to more than 60% depending on the amount and category of the revenue. These are typically withheld by the employer or by the pension fund.

Revenues derived from passive income (dividends, interest, rental income, capital gains) are subject to a specific social contribution of 17.2%. From 2026, the rate of this contribution is increased to 18.6%, except on rental income and real estate capital gain. Individuals affiliated with an EU/Swiss social security system benefit from exemptions following the CJEU’s de Ruyter decision, and are only subject to a contribution of 7.5%.

The social contributions on passive income are levied by the tax authorities, and are generally treated as an income tax for the application of tax treaties, in contrast to the contributions levied on professional income.

Family Quotient System

In France, taxpayers are taxed as a household. The spouses are taxed together without a possibility to opt out, except for spouses who are physically separated and married under a separation regime.

Children are included in the tax household until 18 years old. They can remain in the household until 21 years old without conditions, or until 25 years old if they are students.

The family quotient system (quotient familial) divides household income by number of shares reflecting family composition. The revenue of the household is divided by the number of shares to determine the tax rate applicable to the household.

This mechanism significantly reduces the tax burden for families with children, and is a distinctive feature of the French system.

Scope of Taxation

Non-residents are taxed only on French-source income, including income from French immovable property, professional activities performed in France, French-source pensions, French dividends and capital gains on substantial participations or French real estate.

Withholding Tax Rates

Withholding taxes apply as follows:

• professional income from an activity performed in France – income tax bracket;
• dividends – 12.8%, reducible under applicable treaties;
• interest – 0%; and
• royalties – 25%.

Minimum Tax Rate of Non-Residents

For revenues that are subject to the progressive tax rate, non-residents have a minimum tax rate of 20% for revenues below EUR29,579 and 30% for revenues above this threshold. If the application of the tax bracket leads to a higher tax rate, the higher tax rate is applied. This rule takes into account the fact that France cannot have full knowledge of the contributive capacity of non-residents, which depends on their other worldwide revenues.

Non-residents can demonstrate that they must be taxed at a lower rate, provided that they disclose their worldwide revenues to calculate the effective tax rate at which they must be taxed in France.

Corporate tax residence is determined by three alternative criteria:

• the registered office (siège social) in France;
• the place of effective management, where key strategic decisions are made; or
• the existence of a permanent establishment.

In practice, the place of effective management is often decisive. It is determined by reference to where the board of directors actually meets and makes strategic decisions, rather than mere registration formalities. In treaty situations, tie-breaker rules apply, and the MLI has introduced the possibility of mutual agreement procedures for dual-resident companies.

Domestic Framework

French domestic law does not contain an explicit statutory definition of permanent establishment. The concept has been developed through case law and administrative doctrine, and is broadly aligned with the OECD Model Convention.

Treaty Practice

In treaty contexts, France follows the OECD Model, with a broader agent-dependent definition of permanent establishment, capturing persons who habitually play the principal role that leads to contract conclusion.

Digital Economy Challenges

The digital economy creates specific challenges regarding the concept of taxable presence. In several recent decisions, the Conseil d’État has addressed whether foreign digital platforms create permanent establishments through local activities – an area of ongoing judicial development.        

General Principles

French immovable property income is taxable in France regardless of the recipient’s residence. France distinguishes between revenue from non-furnished property and from furnished property.

Non-furnished property

For non-furnished property, rental income is taxed at the income tax bracket and subject to the social contribution of 17.2%. It can lead to a maximum effective tax rate of 45% (tax bracket) + 4% (exceptional contribution on high revenues) + 17.2 % = 66.2% maximum.

The main categories of expenses that are deductible from the revenue are property expenses, interests, property tax, renovation and amelioration work. Acquisition costs (notary fees, transfer tax) and amortisation are not deductible.

For rental income below EUR15,000 per year, taxpayers may elect for a simplified regime with a 30% allowance on the gross rental income.

Furnished property

For furnished property, rental income is considered a business and commercial income. This allows the taxpayer to deduct depreciation and amortisation of the property and acquisition costs, in contrast to non-furnished property. The net profit is then taxed at the income tax bracket and social contributions at the rate of 18.6% (since 2026).

For rental income below EUR77,700 per year, taxpayers may elect for a simplified regime with a 50% allowance on the gross rental income. The threshold is reduced to EUR15,000 and 30% for short-term rental profits (stays below 30 days), unless the property is classified by the French Ministry of Tourism.

Non-Residents

For non-residents, the tax base is the same as for residents. They are subject to an income tax bracket with a minimum rate of 20% or 30% depending on the amount of revenue (see 2.4 Taxation of Non-Resident Individuals). They are also subject to social contributions at the same rate as residents; however, for people who are affiliated with an EU social security system, the social contribution in France is reduced to 7.5%.

Corporate Tax Rates

Corporate income tax applies at a standard rate of 25%, with a reduced 15% rate on the first EUR42,500 for qualifying SMEs. Under the territorial principle, only profits from French operations or French permanent establishments are subject to corporate income tax.

Dividend Exemption

Dividends derived from a subsidiary are exempt for 95% of their amount, provided that the parent company owns at least 5% of the share capital for a period of two years. The exemption is increased to 99% in tax-consolidated groups.

Participation Exemption

Capital gains on the sale of shares in a subsidiary are exempt for 88% of their amount, provided that the parent company owns at least 5% of the share capital for a period of two years. If the company owns less than 5%, it can demonstrate that the participation is useful for its business and thus claim the participation exemption. The remaining 12% of the capital gain is taxed at the standard corporate income tax rate (25%), leading to an effective tax rate of 3%.

Tax Losses

Tax losses can be carried forward without limitation in time. France applies a limitation of the use of carried-forward losses. If the taxable profit of the year exceed EUR1 million, only 50% of the profit exceeding EUR1 million per year is offsetable by the carried-forward tax losses.

Tax losses can be carried back on the previous tax year to obtain a reimbursement of corporate income tax paid on the previous tax year if the next year is a loss.

Transfer Pricing and Controlled Foreign Company (CFC) Rules

Transfer pricing rules require arm’s length pricing and extensive documentation, including a master file, local file, and country-by-country report for qualifying groups.

CFC rules tax French parent companies on the income of foreign subsidiaries located in jurisdictions where the effective tax rate is below 60% of the French rate, in line with the EU Anti-Tax Avoidance Directive.

Dividends

Dividends are taxed at 12.8% of income tax, unless the taxpayer elects to have them taxed under the income tax bracket (from 0 to 45%). In that case, the tax base of the dividend is reduced by 40%. Dividends are subject to social security contribution at the rate of 18.6%.

Withholding tax is 12.8% for non-resident individuals (no social security contributions) and 25% for non-resident companies. Withholding tax can be eliminated under the EU Parent-Subsidiary Directive if the beneficiary is an EU company holding at least 5% of the share capital.

Double tax treaties can also reduce the domestic withholding tax rate.

Interest

Interest is exempt from withholding tax in France, unless it is paid to a non-cooperative country, in which case the withholding tax rate is 75%.

Royalties

Some royalties are subject to withholding at the corporate income tax rate under domestic law. This is eliminated between associated EU companies under the Interest and Royalties Directive, and can be reduced or eliminated by double tax treaties.

Capital Gains of Individuals

Capital gains on shares and crypto-assets

Capital gains on securities, shares and crypto-assets are subject to a flat tax of 12.8%.

Taxpayers may elect to have the capital gain taxed at the standard income tax bracket; in that case, they can benefit from a deduction of up to 85% depending on the duration of ownership of the company. This deduction is only applicable for shares acquired before 2018.

Social contributions at the rate of 18.6% are applicable in both cases, and are calculated on the gross base before any deduction for duration of ownership.

Non-residents are only subject to capital gains on shares if:

• the underlying company’s assets are composed of more than 50% of French real estate property; or
• the taxpayer owns more than 25% of the share capital in the underlying company.

The tax rate for non-residents is 12.8% without social contributions.

If the company’s assets are composed of more than 50% French real estate property, the capital gain is taxed as a real estate capital gain (19% and social contributions at the rate of 17.2%).

Capital gains on real estate property

Capital gains on French property are taxed at 19%. An additional progressive tax between 2% and 6% might be applicable on gains exceeding EUR50,000.

Capital gains are also subject to social contributions at the rate of 17.2% (7.5% for individuals affiliated with another EU/Switzerland social security system).

The tax base is equal to the difference between the selling price and the price of acquisition. If amortisation and depreciation have been deducted from income tax (furnished property), they are deducted from the acquisition price and thus increase the capital gain.

The acquisition fees and the work that have not been deducted from income tax can increase the price of acquisition for the calculation of the capital gain.

The net capital gain can benefit from a deduction depending on the duration of ownership of the property. Capital gain is fully exempt from income tax after 22 years and from social contributions after 30 years.

Capital gain exemptions exist – in particular for the main residence of the taxpayer, which is exempted from capital gains tax.

Non-residents from a country outside the EU must appoint a tax representative to report their capital gains tax. The tax representative is jointly liable for the payment of the tax with the taxpayer.

Other capital gains

Other capital gains (eg, jewellery, cars, art, etc) are only taxed if the selling price exceeds EUR5,000. The tax base benefits from a deduction of 5% per year of ownership after the second year, leading to a total exemption after 22 years. The tax rate is 19%, and the capital gains are also subject to social contributions at the rate of 18.6%.

Corporate Participation Exemption

See 3.2 Business Profits.

General Framework

Employment income is taxed at progressive rates with a 10% standard allowance on the tax base for professional expenses. Cross-border situations generally follow the OECD Model’s employment income article (Article 15), with specific frontier worker provisions in certain treaties – notably those with Germany and Belgium.

Inbound Expatriate Regime

France’s inbound expatriate regime provides partial exemption on the expatriation premium and foreign-source passive income for up to eight years. This applies to employees who were not previously French tax residents, and represents a significant incentive for attracting international talent.

Remote Working

Remote working raises specific cross-border issues. Bilateral agreements with Belgium, Germany, Luxembourg and Switzerland address the allocation of taxing rights for cross-border teleworkers. For employers, a home office used by an employee may constitute a permanent establishment under the relevant treaty.

France generally follows the provision of the OECD Model Convention.

As of early 2026, France has not yet enacted specific legislation to implement Amount B. The French tax authorities have issued preliminary guidance indicating an intention to adopt the OECD’s standardised return approach for qualifying baseline marketing and distribution transactions.

Implementation is expected through amendments to existing transfer pricing provisions and related administrative guidance. No significant deviations from the OECD framework are anticipated, although France has expressed reservations about the scope of qualifying transactions involving intangibles.

France has been among the strongest advocates for Amount A within the Inclusive Framework, pushing for reallocation of taxing rights towards market jurisdictions. France’s early adoption of a Digital Services Tax in 2019 was explicitly designed as an interim measure pending a multilateral agreement.

As of early 2026, the Multilateral Convention on Amount A remains unsigned. France continues to apply its Digital Services Tax while signalling potential expansion if a global agreement is not finalised. The outcome remains closely tied to broader geopolitical negotiations.

France implemented Pillar Two through the Finance Act 2024, transposing the EU Minimum Tax Directive. The Income Inclusion Rule (IIR) applies from fiscal years beginning on or after 31 December 2023, and the Undertaxed Profits Rule (UTPR) from 31 December 2024.

The rules apply to multinational enterprise groups and large domestic groups with consolidated revenues of at least EUR750 million. The minimum effective tax rate is set at 15% on a jurisdictional basis.

Qualified Domestic Minimum Top-Up Tax

France introduced a Qualified Domestic Minimum Top-Up Tax (QDMTT), meeting the OECD safe harbour standards. This ensures that any top-up tax on low-taxed French entities is collected domestically rather than by another jurisdiction.

Treatment of the Research Tax Credit

A key French feature concerns the Crédit d’Impôt Recherche (Research Tax Credit; CIR), which is classified as a “qualified refundable tax credit” under the GloBE rules. It is therefore treated as income rather than a tax reduction, mitigating Pillar Two’s impact on effective tax rate computations for R&D-intensive groups.

Transitional Provisions

France has adopted transitional safe harbour provisions allowing reliance on country-by-country report data during initial implementation years, reducing the compliance burden during the transition period.

The French Digital Services Tax

France was the first major European country to implement a Digital Services Tax (Law No 2019-759), applying a 3% tax on revenues from two categories of digital activities:

• targeted advertising services based on user data; and
• digital intermediation platforms connecting users.

The tax applies to companies with worldwide digital revenues exceeding EUR750 million and French digital revenues exceeding EUR25 million. It was designed as temporary, pending Pillar One finalisation, but remains in force given negotiation delays.

Audiovisual Tax

Additionally, the taxe video imposes a 5.15% levy on revenues from on-demand audiovisual media services distributed in France. This is earmarked for the Centre National du Cinéma and applies regardless of where the provider is established.

Tax Fraud

Tax fraud is a criminal offence defined as intentional evasion of tax through fraudulent means. It carries up to five years’ imprisonment and EUR500,000 in fines.

Abuse of Law

Tax avoidance is primarily addressed through the abuse of law (abus de droit) procedure. The traditional provision allows the tax authorities to disregard arrangements whose exclusive purpose is to obtain a tax advantage.

France has two definitions of abuse of law:

• fictitious acts (eg, a gift disguised as a sale); and
• tax abuse, defined as using a specific provision in a way that was not the purpose of the law-maker, with the exclusive purpose of getting a tax advantage.

Abuse of law implies a penalty of up to 80% on the tax reassessment.

Since 2019, a “minor abuse of law” (mini abus de droit) provision allows tax authorities to disregard arrangements whose principal (and not exclusive) purpose is tax-driven, significantly broadening the scope of the abuse of law.

France has assembled a comprehensive anti-avoidance framework, combining domestic measures with transpositions of EU directives. The principal mechanisms are:

• the abuse of law procedure, which allows the tax authorities to disregard transactions motivated exclusively or principally by tax benefits;
• CFC rules, which tax French parent companies on the income of foreign subsidiaries in low-tax jurisdictions where the effective rate is below 60% of the French rate;
• transfer pricing rules, which require arm’s length pricing with extensive documentation obligations (master file, local file, country-by-country report);
• thin capitalisation rules, which limit related-party interest deduction through a 1.5:1 debt-to-equity ratio and a 30% EBITDA cap;
• anti-hybrid mismatch rules, transposing the second Anti-Tax Avoidance Directive (ATAD2) and neutralising deduction/no-inclusion and double deduction outcomes; and
• exit taxation, imposing deferred tax on unrealised gains when taxpayers transfer their tax residence outside France.

The French Blacklist

France maintains a list of non-cooperative states and territories (États et Territoires Non Coopératifs, or ETNC), which is updated annually by ministerial decree.

Consequences

Transactions with ETNC-listed jurisdictions face:

• a 75% withholding rate on dividends, interest and royalties; and
• non-deductibility of expenses, unless the taxpayer demonstrates a genuine business purpose.

France also takes into account the EU blacklist of non-cooperative jurisdictions, which influences its own listing decisions. The combination of the ETNC list with CFC rules creates a powerful deterrent against the use of opaque jurisdictions.

Mandatory Reporting Frameworks

France has implemented extensive reporting obligations targeting cross-border arrangements and offshore holdings:

• DAC6 – requires intermediaries to report cross-border arrangements meeting specified hallmarks;
• country-by-country reporting – applies to multinational groups with revenues exceeding EUR750 million; and
• Common Reporting Standard (CRS) – requires financial institutions to report on non-resident account holders.

Individual Disclosure Obligations

Taxpayers must separately report on:

• foreign bank accounts;
• trust holdings; and
• foreign insurance contracts.

Non-compliance triggers penalties and extended assessment periods of up to ten years, reflecting France’s emphasis on international tax transparency.

Key Authorities

The Direction générale des finances publiques (DGFiP) is the primary tax authority. Specialised units include the Direction des vérifications nationales et internationales (DVNI) for large enterprise audits and cross-border matters, and the Direction nationale des enquêtes fiscales (DNEF) for fraud investigations.

Audit and Investigation Powers

Powers available to the tax authorities include:

• desk audits and on-site audits lasting up to one year for large enterprises; and
• unannounced “dawn raids” (perquisitions fiscales) authorised by judicial order, allowing seizure of documents and electronic data.

Tax authorities have access to a variety of data from the other administrations, as well as from banks and, since 2026, from crypto-assets platforms.

Tax authorities are allowed to request administrative documents from contractors of the verified taxpayer (providers, clients, banks, etc) in the course of a tax audit.

Criminal Enforcement

The Brigade nationale de répression de la délinquance fiscale (BNRDF) investigates complex fraud cases in co-ordination with Europol and the OECD’s JITSIC network. The Parquet National Financier (PNF), established in 2013, prosecutes major financial and tax fraud cases.

Administrative Penalties

The administrative penalty framework includes graduated sanctions:

• late filing surcharge – 10%;
• interest on late payment – 0.20% per month;
• bad faith penalty – 40%; and
• fraud penalty – 80% for abuse of law or concealment.

International Specific Penalties

Additional penalties apply to international reporting failures:

• EUR100,000 for a missing country-by-country report;
• EUR10,000 minimum for deficient transfer pricing documentation; and
• EUR1,500 to EUR10,000 per undeclared foreign account, plus proportional penalties up to 80%.

An extended ten-year assessment period applies where assets or accounts were held abroad without proper declaration.

Tax fraud carries five years’ imprisonment and a EUR500,000 fine. Aggravated cases involving offshore accounts or shell companies are punished by seven years’ imprisonment and a EUR3 million fine.

Money laundering of tax fraud proceeds is an autonomous offence carrying up to ten years’ imprisonment. Legal persons are also criminally liable, with fines multiplied by five and potential ancillary sanctions, including publication of conviction and exclusion from public procurement.

Automatic Referral Mechanism

Before 2018, tax authorities had to submit the case to a specific commission (the Commission des Infractions Fiscales) in order to be allowed to refer a tax fraud to the prosecutor. It was not mandatory for the tax authorities to refer a tax fraud.

Since 2018, a reform introduced mandatory automatic referral to the public prosecutor when administrative penalties exceed certain thresholds. Specifically, referral is triggered when a 100% penalty is applied on a base exceeding EUR100,000 or an 80% penalty on a base exceeding EUR200,000. The PNF may also initiate proceedings independently.

Automatic referral also applies when a penalty of 40% is applied for the second time to a taxpayer, provided that the first penalty applied on a base of at least EUR100,000.

Current debates in parliament are discussing the possibility of reducing these thresholds and removing the Commission des Infractions Fiscales, to simplify the process of referral for smaller offences.

Co-Ordination

The Commission des Infractions Fiscales reviews referrals from the tax administration. Tax audits and criminal investigations may run in parallel, with the tax administration authorised to share information with judicial authorities. Taxpayers must carefully manage their rights across both proceedings simultaneously.

France’s international co-operation framework in tax matters rests on multiple legal instruments:

• the OECD Multilateral Convention on Mutual Administrative Assistance (ratified 2004);
• the EU DAC directives (DAC1 through DAC8), progressively expanding automatic exchange to financial accounts, tax rulings, country-by-country reports, cross-border arrangements, digital platforms and crypto-assets;
• bilateral treaty exchange-of-information clauses, modelled on the OECD Model;
• numerous Tax Information Exchange Agreements (TIEAs); and
• the EU Recovery Directive for mutual assistance in tax claim collection.

This multi-layered framework makes France one of the most active jurisdictions in international tax co-operation.

Automatic Exchange

France participates in automatic, spontaneous and on-request exchange of information. Automatic exchange under the CRS covers financial account data with over 100 jurisdictions. France also exchanges country-by-country report data, tax ruling information and reportable arrangement data automatically.

Crypto-Asset Reporting

France has committed to the OECD Crypto-Asset Reporting Framework (CARF) and EU DAC8, introducing automatic exchange on crypto-asset transactions from 2026. France consistently receives positive OECD Global Forum peer reviews on exchange effectiveness.

France participates in the OECD’s International Compliance Assurance Programme (ICAP) for multilateral transfer pricing risk assessments. Joint tax audits are conducted under the Multilateral Convention and the EU joint audit framework introduced by DAC7.

France is a founding member of JITSIC, which facilitates real-time intelligence sharing against aggressive tax planning schemes. It also participates in the EU Fiscalis programme, supporting inter-administration co-operation and capacity building.

France has a well-established mutual agreement procedure (MAP) programme. The legal bases include:

• bilateral treaty provisions modelled on Article 25 of the OECD Model;
• the EU Arbitration Convention for transfer pricing disputes;
• the EU Tax Dispute Resolution Directive (2017/1852), providing a right to arbitration if agreement is not reached within two to three years; and
• the MLI provisions.

The competent authority is the Direction de la législation fiscale (DLF). France actively uses MAPs for transfer pricing, permanent establishment attribution, and income characterisation disputes.

The deadline to submit a MAP request is generally three years from the first notification of the action resulting in taxation not in accordance with the applicable convention. This time limit applies under most bilateral treaties, the EU Arbitration Convention, the EU Tax Dispute Resolution Directive and the MLI. It is advisable to initiate MAP requests early, even before domestic appeal proceedings are completed, to preserve rights and ensure timely resolution.

Mandatory binding arbitration is available through several instruments:

• the EU Arbitration Convention – specifically for transfer pricing disputes, with a two-year resolution deadline;
• the EU Tax Dispute Resolution Directive – broader in scope, with a default decision-making mechanism if states fail to agree; and
• the MLI Part VI – to which France opted in, accepting both the “last best offer” and “independent opinion” approaches, depending on the treaty partner.

General bilateral treaties do not include mandatory arbitration, though some newer conventions incorporate specific arbitration clauses.

France has an active advance pricing agreement (APA) programme administered by the central administration. Unilateral, bilateral or multilateral APAs are available, with bilateral APAs strongly encouraged by the French authorities.

The process involves pre-filing meetings, a formal application with functional and economic analysis, competent authority negotiations for bilateral APAs, and agreements typically covering three to five years with possibility of roll-back. France is among the most active European countries in terms of APA activity.

Tax Rulings

Tax rulings (rescrits fiscaux) provide binding advance positions from the tax authorities on specific situations, including cross-border transactions. This is a valuable tool for taxpayers seeking certainty on novel questions. Tax rulings in France are cost-free. Tax authorities have six months to answer (except for specific rulings).

Co-Operative Compliance

France operates a relation de confiance (co-operative compliance) programme for large enterprises, offering real-time transparency in exchange for faster issue resolution and reduced adversarial audits. The DGFiP has expressed interest in extending this programme to medium-sized enterprises.