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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