Treaty between France and Switzerland: Restriction of the benefit of lower withholding tax rate on dividends for French outward expatriates in Switzerland

On 26 December 2012, the French tax administration updated Guideline BOI-INT-CVB-CHE-10-10-20121226, reducing the scope of the benefit of the lower rate of withholding tax on dividends under the France-Switzerland Income and Capital Tax Treaty (the Treaty).

Under paragraph 6 of article 4 of the Treaty, an individual who is merely subject to lump-sum taxation based on the rental value of his home(s) available to him in Switzerland, shall be deemed not to be resi…