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Commentary

6.2.1 Treaty exemptions for earnings

France

It is beyond the scope of this work to discuss relief from double taxation in detail as that is often the concern of the individual's personal tax position. Reference should be made of Tolley's Global Mobility: Personal Taxes, FR1.8 for detail. However employers may wish to consider that employees posted to France may suffer a double taxation despite the existence of double tax treaty.

It should be noted that most double tax treaties usually provide for relief against taxation of the same income or gains in more than one country. In France there is a significant social security burden. The treaty relief may not address the payment of social security contributions because social security charges are different from taxation.

Some social charges are considered inadmissible for the purposes of double tax treaty relief and inadmissible for credit relief. See Tolley's Global Mobility: Personal Taxes, FR2.4.2 for how this affects tax on rental income.

See 6.1.1 and 6.1.2 for A1/E101 certificates and certificates of coverage.

The current list (and status) of French tax treaties can be found

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