Question 16533 — taxes and duties

Summary

Mr. Karim Ben Cheikh draws the attention of the Minister of the Economy, Finance and Industrial and Digital Sovereignty to the situation of French people established in Burkina Faso, with regard to their tax obligations in their host country and with respect to France. The de facto authorities of this country denounced the tax convention at the beginning of August 2023 according to their declarations and notified its entry into force by note verbale on November 11, 2023 while the terms of this bilateral convention provided that any unilateral denunciation must be carried out before June 30 of the calendar year and that "in this case, the Convention will cease to apply from January 1 of the year following the date of notification, it being understood that the effects will be limited" (article 44 of the convention of August 11, 1965). The MP would like to obtain clarification of the date on which the denunciation of the Burkinabé authorities produces its effects from the point of view of the French tax administration. He draws the attention of the Minister to the fact that the end of this agreement has obvious consequences including tax insecurity for employees of French companies, personnel seconded from national education employed in AEFE approved schools or international transport companies as well as numerous legal uncertainties regarding the liability of inheritances or income from subsidiaries of French companies. The MP notes that in Niger and Mali, the authorities of these countries have similarly denounced the bilateral tax conventions in December 2023. He took note of the Government's response which indicates that in the case of Niger and Mali, the date of March 5, 2024 is retained as the date on which the conventions tax measures no longer produce any effect. He asks whether French nationals from these countries will be able to quickly have precise information and instructions on their tax obligations vis-à-vis the French tax services.

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