The guidance covers income, pensions, and dispute resolution matters under its 2022 tax treaty with Moldova.
The French General Directorate of Public Finance issued new guidance on 19 November 2025 regarding the application of the 2022 income tax treaty with Moldova.
The guidance provides detailed explanations on several aspects of the treaty, including its territorial scope and the rules governing permanent establishments, particularly in relation to construction or assembly sites. It also clarifies the treatment of income from movable capital, such as dividends, interest, and royalties, and addresses taxation issues related to private pensions.
In addition, the guidance explains the procedures for resolving disputes through mutual agreement and arbitration under the treaty framework.
The convention, which includes an annex forming an integral part of the agreement, is designed to eliminate double taxation on income and prevent tax evasion and fraud.
Earlier, the tax treaty between France and Moldova, signed on 15 June 2022, officially entered into force on 23 April 2024.
