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Introduction to the France-USA Tax Treaty


French Tax Law
French American Convention


The tax treaty between France and the United States is a key document for understanding where and how individuals and businesses must pay their taxes. The criteria for tax residence are critical for determining with which country taxpayers have the strongest economic and personal ties, and therefore, where they should be taxed on their global income.


Key Articles on Tax Domiciliation

  • Article 4 – Tax Resident: This article defines what constitutes a tax resident of a contracting state. Tax residency is determined by several criteria, such as the place of permanent home, the center of vital interests (economic and personal), habitual abode, and nationality. This definition is essential for the application of the treaty's provisions.

  • Article 15 – Income from Employment: Addresses the taxation of employment income and establishes that such income is taxable in the country where the professional activity is performed, except for specific exceptions. This can influence the determination of tax residency for individuals working in one country but residing in another.

  • Article 24 – Non-Discrimination: Ensures that citizens of a contracting state are not subject to taxation or any related requirement that is more burdensome in the other contracting state than the taxation and related requirements to which citizens of that other state in the same circumstances are or may be subjected. This article is crucial for ensuring fair treatment of tax residents.


These articles, among others, shape the legal framework governing how tax residents of both countries are identified and taxed. They aim to eliminate double taxation and simplify tax obligations for individuals and businesses operating between France and the United States.


Conclusion and Resources

The France-USA Tax Treaty is a cornerstone for understanding and implementing cross-border taxation. By referring to its articles, taxpayers can more confidently navigate the complexities of tax residency and international taxation.


For further exploration, the complete texts of the treaty are available for consultation:


This article aims to provide an informed overview of the criteria for tax domicile according to the France-USA Tax Treaty. For personalized and specific advice on your situation, consulting a qualified tax attorney is recommended.

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