France – Philippines Tax Treaty
The France-Philippines tax treaty caps withholding on dividends at 15% for portfolio investors and 10% for qualifying direct investment, and interest at 15%. Royalties are taxed at a uniform 15% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 49 active treaties in France's network and one of 28 in Philippines's. The general dividend rate of 15% compares to a median of 15% across France's network and 15% across Philippines's.
Verified data
BIR Tax Treaty Network (bir.gov.ph) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: Philippines Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Philippines) |
|---|---|---|
| Dividends (general) Portfolio investors | 15%saves 10% | 25% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 10%saves 15% | 25% |
| Interest Bank interest, bonds, loans | 15%saves 5% | 20% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 15% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Philippines)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 15% applies to portfolio investors. A reduced rate of 10% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 25%.
Source: Philippines Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 15% withholding under this treaty, compared to the 20% statutory rate. This represents a 5% reduction from the statutory rate.
Source: Philippines Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 15% to 15%.
Source: Philippines Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Philippines Treaty Reference
Comparative Context
🇫🇷France's Network
Among France's 49 active treaty partners, the 15% general dividend rate ranks 37th (median: 15%).
| Partner | Rate |
|---|---|
| Netherlands | 15% |
| Norway | 15% |
| New Zealand | 15% |
| Philippines (this treaty) | 15% |
| Pakistan | 15% |
| Poland | 15% |
| Portugal | 15% |
🇵🇭Philippines's Network
Among Philippines's 28 active treaty partners, the 15% general dividend rate ranks 8th (median: 15%).
| Partner | Rate |
|---|---|
| Germany | 15% |
| Denmark | 15% |
| Spain | 15% |
| France (this treaty) | 15% |
| Israel | 15% |
| Italy | 15% |
| Japan | 15% |