List of non EU territories with 3 percent tax administrative assistance agreement

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

Albania Ecuador Libya Sri Lanka
Algeria Egypt Liechtenstein St Barthelemy
Andorra Ethiopia Macedonia St Kitts & Nevis
Anguilla French Polynesia Madagascar St Marin
Antigua & Barbuda Gabon Malawi* St Lucia
Argentina Ghana Malaysia St Martin
Armenia Georgia Mali* St Pierre & Miquelon
Austrailia Gibraltar Mauritania St Vincent and the
Azerbaijan Guernsey Mauritius Grenadines
Bangladesh Guinea  Mayotte Switzerland
Bahamas Hong Kong Mexico Syria
Bahrain Iceland Monaco* Taiwan
Belize India* Mongolia Thailand*
Benin* Indonesia* Morocco* Togo*
Bermuda Iran* Namibia* Trinidad & Tobago
Botswana Isle of Man New Caledonia Tunisia*
Brazil* Japan New Zealand Turkey*
Burkina-Faso* Israel Niger* Turks & Caicos Islands
Cameroon* Ivory Coast* Nigeria Ukraine
Canada Jamaica Norway United Arab Emirates
Caiman Islands Jersey Pakistan Uruguay
Cent. African Republic* Jordan Philippines* USA
Chile Kazakhstan Qatar Uzbekistan
China Kenya Quebec Vanuatu
Congo Korea (S) Russia Venezuela
Cook Islands Kuwait Senegal* Vietnam
Costa Rica Lebanon* Singapore Zambia*
Dominican Republic Liberia South Africa Zimbabwe

(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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