France-Singapore DTAA: Double Tax Avoidance Agreement

Learn key provisions of the France-Singapore Double Tax Treaty, including specific rules on taxation of various types of income, applicable tax rates, principles used to determine tax residency status, and provisions for the elimination of double taxation. Useful guidance for minimizing the tax burden of entrepreneurs and companies doing cross-border business in France and Singapore.
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France-Singapore DTAA: Double Tax Avoidance Agreement

As key trading partners, France and Singapore enjoy strong economic ties. At present, Singapore is one of France’s leading trading partners in the Asia region, while France is Singapore’s second-largest trading partner in the EU. France’s trade with Singapore in 2019 amounted to EUR 12.1 billion. Singapore is also the most popular Southeast Asian destination for French investors.

Many French companies use Singapore as their regional headquarters for expanding their business to the Asian market. Among these are ST Microelectronics, Murex, Engie, INSEAD, Safran, Nestle, CMA-CGM, Dassault Systemes, Airbus, Thales, BNP Paribas, Alcatel-Lucent, and several other well-known firms.

These companies value Singapore’s regional connectivity, state-of-the-art infrastructure, favorable taxation rules, stable legal and political framework, and pro-business environment. Given this deep mutual economic relationship, it was important for both countries to develop a framework to mitigate the tax burden that arises in bilateral business activities.
key facts about France-Singapore DTAA

What is the France-Singapore Double Tax Treaty?

The main goal of the France-Singapore Double Taxation Agreement (DTAA) is to establish the principles and rules that determine which country has the primary right to tax an individual or a company; once the determination is made then the other country does not impose any tax in order to eliminate double taxation. Note that the determination of the tax residency also helps prevent tax avoidance.

This DTAA regulates a major issue for cross-border individuals and businesses — avoiding the taxation of the same income by both countries. If you plan to incorporate a company in Singapore and do business with France, this guide will help you understand the tax treatment of various types of income that may arise as a result of business activities in France.

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Overview of Singapore's Bilateral Agreements With France

Below are the main bilateral agreements concluded between France and Singapore, in effect as of June 2022.

Scope of the Singapore-France Double Tax Treaty

The France-Singapore DTAA extends to individuals, corporate entities, and any other body of persons who are tax residents of one or both of the contracting states (i.e. France and Singapore).

What Taxes Will I Owe Under the France-Singapore Double Tax Avoidance Agreement?

The tax you owe will depend on the country where you have to pay the tax which further depends on the type of income involved. Taxes on various types of income are described in the following sections.

How France-Singapore DTAA Avoids Double Taxation?

The DTAA provides special instruments to ease the tax burden imposed by the governments of both states on individuals and corporate entities. Applying a foreign tax credit or other tax exemption methods can help individuals and enterprises avoid being taxed twice on the same income, or at least reduce their tax liability. The amount of tax credit is generally limited to the amount of tax paid abroad. However, it should not exceed the tax due in the state where it should be credited (i.e., whichever tax is lower).

A claim for foreign tax credit in Singapore, along with additional documentation, is subject to review by the Inland Revenue Authority of Singapore on a case-by-case basis.

Under the tax exemption method, taxable income is subject to tax only in one country, without submitting any specific application to the tax authority of either country.

In Which Country Will the Income be Taxed?

The France-Singapore double taxation avoidance agreement specifically states where different types of income are subject to tax. Essentially, the place of taxation determines the rate of tax applicable to each type of income as follows:

Type of income or payment

Where it is taxed

Income from immovable property

Taxed in the state where the property is situated.

Business profits

Taxed in the state where a company is a resident.

Permanent Establishment profits

Taxed in the state where it carries on business activities, but only in the amount attributable to that PE.

Profits from shipping and air transport

Taxed in the state where a company is managed and controlled. May also be taxed at reduced rates in the state where ships or aircraft are operated.


May be taxed in the state where the recipient resides and in certain cases in the state where dividends arise. If so, DTAA ensure elimination of double taxation.


May be taxed in the state where the recipient resides and in certain cases in the state where interest arises. In case of double taxation, DTAA provides recourse.


May be taxed in the state where the recipient resides and in certain cases in the state where royalties arise. In case of double taxation, DTAA provides recourse.

Capital gains

May be taxed in the state where the place of effective management of the receiving company is situated, or in the state where immovable property is situated.

Employment income

May be taxed in the employee’s state of residency and in certain cases in the state where employment is exercised, at reduced rates.

Directors’ fees

Taxed in the state where the company (paying the director’s fees) resides.


Taxed in the state where the recipient resides.

Payments to students and trainees

Taxed in the state where the recipient resides. May be taxed in the state of education if the payment does not fall under exemptions.

Protect Your Income From Excessive Taxation

To effectively grow your business and maximize profits, it’s essential to understand the tax benefits available to you and your business. If you’re considering incorporating your company in Singapore, can help you navigate the process by helping select the correct corporate structure that will minimize your taxes while fully complying with all government laws, regulations, and DTAAs.
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Singapore and France are strong economic partners. A significant step forward in their bilateral relations was made when the EU-Singapore FTA was signed. As a result, a growing number of French companies have expanded their business to Singapore. The DTAA signed between the two countries helps reduce the tax burden for such companies by eliminating double taxation.

From our day-to-day communication with clients, it is clear that taxes are a major concern for all businesses, big or small. The DTAA provisions are very generous but the rules for utilizing these provisions can be complicated. Therefore, it is important to involve qualified experts who can craft a personalized and holistic approach to optimize your taxes. Contact our team if you need assistance in claiming double-tax relief in Singapore.


In this article we’ve provided some basic rules for how to apply the provisions of the DTAA. However, the above-mentioned scenarios for taxation of various types of income cannot be considered exhaustive. We suggest you contact your tax consultant to advise on your particular case.

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