The France–Mauritius tax treaty

After a move to Mauritius, some income may remain taxable in France. A pension, rent from an apartment and portfolio dividends may each follow different rules. The tax treaty determines which country may tax each type of income and how double taxation is relieved.

The French tax authority’s BOFiP entry records the treaty’s origins: signed in 1980 and amended in 2011. For a current situation, also consult the synthesised text published by the MRA, which incorporates the effects of the Multilateral Instrument. This version is a reading aid; the authentic legal instruments remain authoritative.

Start with your tax residence

Before comparing tax rates, establish where you are tax resident. A residence permit concerns immigration. Tax residence is determined under each country’s rules and, if both countries consider you resident, under the treaty.

France considers factors including your family home, professional activity and main economic interests. You can therefore remain tax resident in France while spending part of the year abroad. Residence is also assessed individually within a couple (DGFiP, non-residents of France).

If both countries treat you as resident, Article 4 sets out successive tests: a permanent home, closer personal and economic ties, habitual abode, then nationality. If those tests do not resolve the position, the authorities must reach an agreement. Applied in turn, these tests determine your residence for the purposes of the treaty.

Different income, different rules

The situations below concern an individual who is resident in Mauritius for treaty purposes. Each category still has its own conditions to examine.

Your situation	What matters
You rent out an apartment in France	France retains the right to tax the rent. French tax obligations relating to the property continue after a move abroad.
You receive dividends from a French company	French taxation may still apply. For an individual, the treaty caps French tax at 15% of the gross dividend. French withholding for a non-resident individual is 12.8% (DGFiP), below the cap, so that is the rate applied.
You receive French-source interest	The treaty also permits taxation in the source country and sets no maximum rate. It does not provide a general exemption for individuals. Under French law, interest paid to a person domiciled outside France bears no social charges. Nor does it bear withholding tax, unless it is paid in a non-cooperative state or territory (DGFiP); Mauritius is not on the April 2026 list.
You work in both countries	Mauritius may tax the salary. France may also tax the part earned from work performed in France, unless all three conditions of Article 15(2) are met.

These distinctions follow Articles 6, 10, 11 and 15 of the treaty. For rent, the DGFiP also distinguishes furnished and unfurnished lettings, which have different reporting requirements.

Who may tax a capital gain?

The treaty allocates the right to tax a gain according to what is sold (Treaty, Article 13, and Protocol, Article 1, point 6).

French real estate and property companies

France may tax a gain on the sale of real estate located in France. The Protocol extends this to shares in a company holding real estate in France, where French law taxes their sale in the same way as a property sale.

Under French law, the gain bears a 19% levy whatever the seller’s country of residence, plus social charges of 17.2%. For a person affiliated to a compulsory social-security scheme of a European Economic Area country other than France, or of Switzerland, the social charges are limited to the 7.5% solidarity levy (DGFiP, real-estate gains). These rates apply to the gain after the allowances for length of ownership, which differ for the 19% levy and for social charges. A further tax, calculated on a scale from 2% to 6%, applies where the net taxable gain exceeds €50,000, except on building land (DGFiP, form 2048-IMM guidance). Exemptions open to non-residents depend on conditions to be checked with the notary handling the sale.

Other shares and securities

Gains on other securities are taxable only in the seller’s country of residence, in this case Mauritius. The Protocol makes one exception: France may tax the sale of a substantial interest in a French company. An interest is substantial where the seller, alone or with associated or related persons, holds directly or indirectly shares giving rights to 25% or more of the company’s profits.

Under French law, a non-resident is taxed on such gains only if they held more than 25% of the company’s profit rights, together with their spouse and the ascendants and descendants of either, at any time during the five years before the sale. The rate is then 12.8% (BOFiP, BOI-RPPM-PVBMI-10-30-20). France can therefore tax the gain only if both the treaty condition and the French-law condition are met. On the Mauritius side, our foreign income guide covers the exemption for gains on securities.

Which French pensions remain taxable in France?

Basic and compulsory supplementary pensions, including those earned in private-sector employment, remain taxable only in France. Other pensions follow different rules.

Basic and compulsory supplementary pensions

French social-security pensions are taxable only in France under Article 18(2). The DGFiP includes statutory basic schemes and compulsory supplementary schemes, notably Agirc-Arrco, in this category (DGFiP, pension categories).

The MRA confirmed this treatment in ruling TR 219: the taxpayer’s French social-security pensions were not taxable in Mauritius, including when remitted there.

Other private pensions and public-service pensions

Other private pensions are generally taxed in the country of residence. However, Article 18(3) permits taxation in the source country where the recipient is not subject to tax on that pension in their country of residence. The tax treatment of the pension is therefore examined in both countries, including when it remains in a French account.

Public-service pensions follow Article 19, with provisions involving nationality. Annex 1 of the French 2041-E guidance distinguishes the three categories. Ask each pension provider to confirm the nature of its payments before agreeing the treatment with your tax adviser.

How is double taxation relieved?

The treaty does not use one method for every category. Depending on the income, it provides an exemption in one country or a credit for tax paid in the other. The credit is capped; it is not an automatic refund of all foreign tax. For a Mauritius resident, rent and real-estate gains that France may tax under the treaty are exempt from Mauritian tax, although the treaty provides for Mauritian tax on other income to be computed at the rate that applies to total taxable income under Mauritian law. French dividends and interest, by contrast, may be taxed in Mauritius on the gross amount, with a credit for the French tax up to the Mauritian tax on that income; the same applies to other income listed in Article 24, such as directors’ fees and royalties (Treaty, Article 24).

In TR 219, the MRA confirmed exemption for the taxpayer’s French property income, provided it had been taxed in France, while retaining the requirement to file an annual Mauritius return. You may still need to file in both countries even if you are not taxed twice.

How do these rules work in practice?

These illustrative examples concern a Mauritius resident for treaty purposes and use the rates published by the DGFiP for income received in 2025. They are not a calculation of your own tax.

Dividends from a French company

A French company pays a gross dividend of €10,000. Withholding at 12.8% comes to €1,280; a non-resident pays no French social charges on it. If you file a French return for other income, these dividends are reported on it too. If the dividends are your only French-source income, they must still be declared above €250,000 for a single, divorced, widowed or separated person, or €500,000 for a couple taxed jointly (DGFiP, dividends).

If the dividends are taxable in Mauritius under the rules in our foreign income guide, the €1,280 is credited against Mauritian tax, up to the tax due on those dividends.

Rent from a flat in France

A household’s only French-source income is the rent from an unfurnished flat in metropolitan France: €12,000 for the year, excluding service charges. As this does not exceed €15,000, the micro-foncier regime applies, with a flat 30% allowance: net taxable income is €8,400 (DGFiP, micro-foncier).

A non-resident’s tax on this rent is computed on the French scale with a minimum rate of 20% up to €29,579 of net taxable income: here it comes to €1,680 (DGFiP, minimum rate). A lower average rate, based on your worldwide income, can be claimed on the return with supporting documents (DGFiP, average rate).

Social charges of 17.2% are added on unfurnished lettings (18.6% on furnished ones). A person affiliated to a compulsory social-security scheme of a European Economic Area country other than France, or of Switzerland, pays only the 7.5% solidarity levy (DGFiP, property income). In Mauritius the rent is exempt, but it goes on your annual return if you have to file one.

An Agirc-Arrco pension

As explained above, an Agirc-Arrco pension counts as a social-security pension for treaty purposes and stays taxable only in France, even when it is paid into an account in Mauritius. French withholding and the annual French return are covered in our guide to retiring in Mauritius.

Practical steps to prepare

Gather residence evidence, pension-provider statements, income statements and proof of tax already withheld.

The MRA issues a Tax Residence Certificate for the relevant income year, following an application and assessment. For certain treaty benefits on French income, the DGFiP provides residence certificate form 5000, with supporting forms depending on the income and procedure. Check the applicable process and deadlines with the paying institution.

The treaty covers taxes on income and capital. It does not govern inheritance or gift taxes. Under French law, Article 750 ter of the French tax code charges French inheritance and gift duties on assets in France passed on by a person whose tax domicile is outside France. Assets abroad are also chargeable where the heir, legatee or donee receiving them has their tax domicile in France on the day of the transfer and has had it for at least six of the ten years before the year of the transfer. Securities issued by a company with its registered office in France count as assets located in France for these rules, even when held with a foreign bank (BOFiP, BOI-ENR-DMTG-10-10-30). Treaty benefits remain subject to its conditions of application and its anti-abuse rules.

These tax rules need to be taken into account when organising your accounts and investments. Our Mauritius page explains the broader setting; the tax treaty directory links to agreements with other countries.