The French General Directorate of Public Finance has provided guidance on the termination of the 1972 tax treaty with Mali.
The treaty with Mali, signed on 22 September 1972 in Paris and effective from 1974, will be deemed terminated by France from 1 January 2025.
According to the guidance, the treaty no longer applies to income acquired on or after 5 March 2024. It remains applicable to income acquired up to and including 4 March 2024, even if received after that date. Dividends are considered to have been acquired before 5 March 2024 if the decision to distribute them was made by 4 March 2024. Interest and royalties are deemed acquired before 5 March 2024 if they pertain to periods ending on or before 4 March 2024; for periods ending after, they are only considered for the portion up to 4 March 2024. Capital gains are deemed acquired before 5 March 2024 if the property was disposed of on or before 4 March 2024.
