List of non EU territories with 3 percent tax administrative assistance agreement
01 November 2021
List of non-EU territories which have an administrative assistance agreement with France for the application of Article 990 E-3 o (French tax code), relating to the annual 3% tax on entities holding French real estate
||St Kitts & Nevis
|Antigua & Barbuda
||St Pierre & Miquelon
||St Vincent and the
||Trinidad & Tobago
||Isle of Man
||Turks & Caicos Islands
||United Arab Emirates
|Cent. African Republic*
(1) This list was issued by the French Tax Administration as at 1 January 2012 and will no doubt be updated at some stage. It is specific for the application of 3% exemptions under 3 o of Art 990 E of the Code Général des Impôts.
(2) This list does not include any EU countries as these all have double tax treaties with France containing the relevant agreements to allow companies and entities established in these countries to file for the 3% tax exemption. Denmark has revoked its double tax treaty with France but Danish entities continue to benefit from this exemption possibility.
(3) When dealing with any territories in particular, it is important to check the current situation. For instance, although the British Virgin Islands were on this official list, they were blacklisted with effect from 1 January 2014.
(4) This list is not valid (at the time of going to print) for the purposes of confirming the scope of the minimum taxation under Article 123 bis of the Code Général des Impôts.
(5) The double tax treaty with China excludes Hong Kong and Macao.
(6) The double tax treaty with Luxembourg excludes Luxembourg holding companies.
(7) The double tax treaty with the Netherlands excludes the Netherlands Antilles.
(8) The double tax treaty with the United Kingdom excludes the Isle of Man, Gibraltar and the Channel Islands.
(9) *The clause of assistance in the treaties with the countries marked by an asterisk does not apply to “transparent” legal entities (entités juridiques dépourvues de personalité morale).
This publication has been carefully prepared, but it has been written in general terms and should be seen as containing broad statements only. It cannot be relied upon to cover specific situations without obtaining professional advice.
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