France–Russia Tax Treaty Suspended: What Russian Residents in France Must Know!

The bilateral tax treaty between France and Russia (Treaty of 26 November 1996), which aimed to prevent double taxation, has been officially suspended as of August 8, 2023.

This results from:

• Russian Presidential Decree No. 585 of August 8, 2023,

• Ratified by Law No. 598-FZ on December 19, 2023,

• Followed by France’s reciprocal suspension, based on Article 55 of the French Constitution,

• As confirmed by the French Ministry of Foreign Affairs (communiqué of June 23, 2024) and the BOFiP update (BOI-INT-CVB-RUS-20241023, published on October 23, 2024).

  
  

Consequences for Russian Tax Residents Living in France

1. Double Taxation Now Applies: Russian-source income (salaries, dividends, interest, royalties, capital gains) is now fully taxable in both Russia and France.

   
   

2. No More Tax Credit in France: While Article 23 of the treaty remains formally in force (regarding elimination of double taxation), it is no longer applicable in practice, as most income is no longer taxed under treaty provisions.

   
   

3. Deduction Instead of Credit: Russian withholding tax can no longer be claimed as a tax credit on your French return.

   
   

Retroactive Effect to 2023

The treaty suspension is applied retroactively from August 8, 2023, including to income received in 2023.

⚠️ This retroactive effect is - to our view - legally questionable

Need help? If you need assistance with your French tax declaration, international income reporting, or have any questions about your cross-border situation, I’m here to help. Feel free to get in touch for tailored support.