J'ai fait appel à Maître Uzan dans le cadre d'une procédure fiscale longue et techniquement complexe. Analyse rigoureuse du dossier, réponses précises dans des délais parfois très courts, et surtout une vraie capacité à maintenir un dialogue constructif avec l'administration plutôt qu'à durcir inutilement les positions.
Il a pris le temps de m'expliquer chaque étape et les options possibles, sans jargon et sans promesses excessives. Le dossier s'est conclu par une issue négociée.
Un accompagnement sérieux, du premier échange jusqu'au suivi complet de l'exécution. Je recommande sans réserve.
Foreign Interest or Dividends
By Marc Uzan, French tax lawyer in Paris
How Can I Declare My Foreign Interest or Dividends and Optimise Their Taxation?
Tax lawyer at the Paris Bar since 2008 – exclusive tax law practice, including foreign investment income
Summary
- Mandatory reporting on form 2047 + transfer to form 2042
- Default taxation: single flat-rate levy (PFU) of 31.4% since the 2026 Social Security Financing Act (30% previously), or, on option, the progressive scale (box 2OP)
- Tax credit: lines 8VL or 8TK depending on the applicable treaty
- Tax lawyer: recovery of the credit, tax audits, application of bilateral treaties
What are the reporting obligations for foreign interest or dividends when you are a French tax resident?
- Form 2047 is in principle required: a tax resident of France must in principle report their foreign-source interest and dividends, even if this income has already been subject to withholding tax in the country of origin.
- Carrying over to return 2042 according to the type of income: dividends are in principle carried over to box 2DC (or 2TS where they do not qualify for the 40% allowance), and interest to box 2TR. This makes it possible to calculate the applicable French tax.
- Claiming the tax credit on lines 8VL / 8TK: to avoid double taxation, the tax credit corresponding to the foreign tax, within the limit set by the tax treaty, is in principle to be reported so that it can be credited against French tax.
- Deadlines and supporting documents: the return is in principle filed before the end of May or early June, depending on the département; it is prudent to keep the documents proving the foreign withholding tax.
How do I complete form 2047 step by step to report my foreign dividends?
- “Foreign investment income” section: this is in principle the section of form 2047 used for dividends and interest.
- Gross amount: the amount received is in principle stated before deduction of the foreign withholding tax.
- Conversion into euros: in principle at the exchange rate on the day of receipt (for example the ECB rate).
- Carrying over to the main return (2042): the gross amount is in principle carried over to box 2DC for dividends.
- Tax credit: its amount is in principle entered on line 8VL if the tax treaty provides for it.
- Supporting documents: it is prudent to keep the evidence of the withholding tax, so that it can be produced if the tax authorities request it.
- Treaty caps: in principle, the part of the withholding tax that exceeds the rate provided for by the treaty cannot be set off against French tax.
Flat tax (PFU) at 31.4% or option for the progressive scale: which taxation should I choose for my foreign interest and dividends?
| Option | Income tax rate | Social levies | When to use it? | Box to tick |
|---|---|---|---|---|
| Flat tax (PFU) | 12.8% | 18.6% | Often more favourable where the marginal tax rate is high (no 40% allowance on dividends). | None (automatic) |
| Progressive scale | 0% to 45% | 18.6% | May be more favourable if your marginal rate is low, in particular thanks to the 40% allowance on dividends; the option applies to all the income and gains concerned for the year. | Box 2OP |
How can double taxation be avoided through tax treaties and the tax credit on lines 8VL/8TK?
- Applicable bilateral treaty: it sets the treaty rate that caps the tax credit granted by France (often 15% for dividends, 10% for interest).
- Crediting via a tax credit: Depending on the treaty, France grants you a credit equal either to the tax paid abroad, up to the corresponding French tax (box 8VL), or to the French tax on the income (box 8TK).
- Accurate reporting on forms 2047 and 2042: in principle, the gross amount is entered, then, depending on the treaty, either the tax credit on line 8VL or the amount of the income on line 8TK where the credit is equal to the French tax; it is prudent to keep the supporting documents.
What I see in my cases
The foreign dividends and interest I see in my cases often involve large amounts, particularly when they come from funds or portfolios held abroad. Tax treaties almost always offer optimisations, often significant ones, provided the tax credit is correctly calculated and documented. The tax authorities know these mechanisms poorly and tend to refuse a poorly presented credit: I therefore prepare these returns so that they are solid from the outset.
The error I come across most often concerns the method: the tax credit and the exemption with the effective rate rule are sometimes confused, whereas, for dividends and interest, treaties in principle provide for a tax credit (box 8VL or 8TK depending on the treaty). Another point to watch: when the tax withheld abroad exceeds the rate provided for by the treaty, the French tax credit is capped at that rate; the excess is lost in France, and its recovery depends, where applicable, on steps taken in the other country, with the help of a local professional.
Why entrust the reporting of my international financial income to a tax lawyer?
- Checking treaties and applicable rates: The tax lawyer identifies the applicable treaty and calculates the tax credit available in France, within the treaty rates.
- Optimizing taxation: They advise you on the choice between the flat tax and the progressive scale, and help you correctly incorporate expenses and tax credits.
- Securing the file in the event of an audit: In the event of an omission or error, the lawyer prepares a solid file with the necessary supporting documents to limit penalties.
FAQ
Why is France claiming tax from me when tax has already been withheld at source on my foreign dividends?
Because France taxes the worldwide income of its tax residents. Even if you have paid withholding tax in the country of origin, this income is in principle to be reported in France.
In return, you can claim an equivalent tax credit, provided that a tax treaty provides for it. This credit is generally limited to the amount of French tax or the amount actually paid abroad. Without this entry on line 8VL or 8TK, the same income may be taxed twice.
How do you complete form 2047 online for interest received on a US account?
In principle, the gross amount of interest is entered in the "revenus de capitaux mobiliers étrangers" (foreign investment income) section of form 2047, after conversion into euros at the rate on the date of receipt (for example the ECB rate), then transferred to box 2TR of form 2042.
If tax has been withheld in the United States, the corresponding tax credit, within the limit set by the treaty, is in principle to be entered on line 8VL. It is useful to keep the supporting documents for the foreign withholding, so that they can be produced if necessary.
What should I do if I forgot to report foreign dividends for 2022 and have just received a reminder from the tax authorities?
Before taking any step, it is advisable to consult a lawyer to analyse your situation: depending on the case, an amended return for 2022, accompanied by forms 2047 and 2042 and the supporting documents for the foreign tax paid, may be an appropriate solution. A spontaneous correction may, in some cases, help to limit surcharges.
If the reminder is a formal notice or part of a reassessment procedure, the involvement of a tax lawyer may be useful to limit, depending on the case, the penalties and to defend your file in the event of an audit.
Simple case study on foreign dividends: €800,000 received from an American company
- Dividend statement: you receive €800,000 gross through your broker on a foreign account.
- Form 2047: the gross amount in euros (converted at the ECB rate on the payment date) is in principle entered in the section "Revenus de capitaux mobiliers étrangers" (foreign investment income).
- Form 2042: the gross amount (€800,000) is in principle transferred to box 2DC (dividends).
- Tax credit: if tax was withheld at source, it is in principle entered on line 8VL (credit capped at the treaty rate, i.e. 15% for US dividends).
- Supporting document: it is useful to keep the transaction statement and the notice of foreign withholding tax.
Glossary
- PFU (prélèvement forfaitaire unique, single flat-rate levy): flat-rate taxation of 31.4% since the 2026 Social Security Financing Act (12.8% income tax + 18.6% social levies), compared with 30% previously.
- Box 8VL / 8TK: allows you to benefit from the tax credit and avoid double taxation.
- Tax treaty: an agreement between France and another country to limit double taxation (e.g. the France-USA treaty).
- Box 2OP: box ticked when opting for the progressive scale; the option is global and may be worthwhile, in particular, for households with a low tax rate.
Key takeaways
- Even if you have already paid tax abroad, reporting in France is in principle mandatory.
- The tax credit ensures that you do not pay tax twice on the same income.
- In principle, the foreign tax is not deducted on form 2047: the gross amount is reported and the credit is applied on line 8VL or 8TK.
Further reading
CGI, article 158, 3-2: 40% allowance on dividends
Article 158, 3-2 of the French General Tax Code (Code général des impôts) allows a 40% allowance on foreign dividends when the progressive scale option is chosen. This regime applies only if the distributing company is located in the EU or in a State with which France has a tax treaty, and if the dividends are distributed under regular conditions. The allowance is incompatible with the flat tax (PFU).
Credit equal to the foreign tax or to the French tax, depending on the treaty
The credit may be equal to the tax actually paid abroad, up to the French tax due on the income concerned (box 8VL): this is the general case for dividends and interest. It may also be equal to the French tax on the income (box 8TK), which neutralises the French tax on that income. The choice depends on the applicable treaty.
A close reading of each treaty is essential to avoid double taxation or a reporting error.
