The income tax treaty between Finland and France enters into force on 28 August 2026. Signed on 4 April 2023, the treaty replaces the bilateral convention that had governed cross-border taxation between the two countries since 1970.
Taxes covered
On the French side, the treaty applies to income tax, corporation tax, contributions on corporation tax, and the general social contributions and contributions for the repayment of the social debt. On the Finnish side, it covers state income taxes, corporate income taxes, municipal tax, church tax, and tax withheld at source from interest.
What practitioners should do now
The treaty is now in force. Practitioners advising clients with Finnish or French cross-border interests should review existing structures against the new treaty provisions, given the substantial time that has elapsed since the 1970 treaty and the significant developments in OECD model practice over that period. Updated withholding rate certificates, residency confirmations and permanent establishment assessments may all be required before the new rules take effect.