The French General Directorate of Public Finances published a guidance, on 23 October 2024, for the application of the France and Russia income tax treaty following the suspension of several provisions of the agreement.

Despite the suspension, which took effect on 8 August 2023, certain treaty benefits may still apply to income associated with periods or events occurring prior to this date.

The treaty remains applicable to dividends if the decision to distribute them was made before the suspension date;

Interest and royalties – which includes payments for intellectual property and financial transactions – still qualify for treaty benefits if they relate to periods that ended before the suspension.

Capital gains are covered under the treaty as long as the sale occurred prior to the suspension.

Business profits and income from independent services are covered under the treaty, provided these relate to a tax year of 12 months or less that began before the suspension date.

Salaries, pensions, and public remuneration are eligible for treaty benefits if they pertain to periods ending by 30 September 2023.

Capital subject to the French real estate wealth tax remains eligible for treaty benefits if it was held as of 1 January 2023. This allows individuals with real estate investments to maintain their tax advantages despite the suspension of the treaty.

Earlier, France issued a notice in Official Journal No. 0147 on 23 June 2024 regarding the partial suspension by the Russian Federation of the convention between France and Russia, effective from 8 August 2023.

On 8 August, 2023, the Russian Federation had suspended the application of Articles 5 to 22 and 24 of the convention between the two nations to prevent double taxation and tax evasion.

The treaty was signed in Paris on 26 November 1996, and published by Decree No. 99-431 of 20 May 1999, as well as points 2 to 9 of the related protocol.