Key Benefits:
President of the Republic,
On the report of the Prime Minister and the Minister for Foreign Affairs and International Development,
Considering the Constitution, in particular articles 52 to 55;
Vu la Act No. 82-1092 of 23 December 1982 authorizing the approval of a convention between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income tax and inheritance tax (as a whole protocol), signed in Paris on 18 February 1982;
Vu la Act No. 94-883 of 14 October 1994 authorizing the approval of the avenor to the 18 February 1982 agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income tax and inheritance tax (a combination of interpretative letters) ;
Vu la Act No. 2012-319 of 7 March 2012 authorizing the approval of the Avenor to the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation in respect of taxes on income, inheritance and fortune;
Vu le Decree No. 53-192 of 14 March 1953 amended on the ratification and publication of international commitments undertaken by France;
Vu le Decree No. 83-586 of 28 June 1983 publishing the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income and inheritance taxes (as a whole Protocol), signed in Paris on 18 February 1982;
Vu le Decree No. 89-375 of 12 June 1989 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia, renewing the agreement of 18 February 1982 with a view to avoiding double taxation on income and inheritance taxes, signed on 20 December 1988 and 22 February 1989;
Vu le Decree No. 95-987 of 28 August 1995 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia on the extension of the agreement of 18 February 1982 with a view to avoiding double taxation on income and inheritance taxes, signed on 3 January 1994 and 3 May 1995;
Vu le Decree No. 95-988 of 28 August 1995 issuing the amendment to the 18 February 1982 agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income and inheritance taxes (a combination of interpretative letters signed on 16 June and 31 October 1993), signed in Riyadh on 2 October 1991;
Vu le Decree No. 99-453 of 28 May 1999 issuing the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia to renew the agreement of 18 February 1982 with a view to avoiding double taxation on income tax and succession, in the form of an exchange of letters signed in Paris on 9 September 1998 and in Riyadh on 2 January 1999;
Vu le Decree No. 2003-1231 of 17 December 2003 publishing the agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia on the renewal of the agreement of 18 February 1982 with a view to avoiding double taxation in respect of income and inheritance taxes (as a whole protocol), signed on 14 April and 6 July 2003;
Vu le Decree No. 2009-725 of 18 June 2009 publishing the agreement by exchange of notes between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia for the renewal of the agreement with a view to avoiding double taxation on income tax and estates signed on 18 February 1982, signed in Paris on 27 November 2008 and 30 December 2008;
Vu le Decree No. 2012-868 of 6 July 2012 issuing the amendment to the agreement between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia with a view to avoiding double taxation on income, inheritance and property taxes, signed in Paris on 18 February 2011,
Decrete:
The agreement in the form of an exchange of letters between the Government of the French Republic and the Government of the Kingdom of Saudi Arabia relating to the renewal of the agreement of 18 February 1982 with a view to avoiding double taxation on income and inheritance taxes (a whole protocol), signed on 18 February 1982, signed in Paris on 26 December 2013 and in Riyadh on 25 May 2014, will be published in the Official Journal of the French Republic.
The Prime Minister and the Minister for Foreign Affairs and International Development are responsible, each with respect to him, for the execution of this decree, which will be published in the Official Journal of the French Republic.
AGREEMENT
SUBSTANCE OF LETTERS TO THE GOVERNMENT OF THE FRANÇAISE REPUBLIC AND GOVERNMENT OF THE SAUDI ARAB ROYAUME RELATING TO THE UNITED NATIONS RECOGNITION OF THE CONVENTION
FRENCH REPUBLIC
MINISTRY OF BUSINESS
Minister
Paris, 26 December 2013
His Royal Highness
Prince Saoud AL FAYSAL,
Minister for Foreign Affairs
of the Kingdom of Saudi Arabia
Highness,
On February 18, 1982, our two governments signed a convention to avoid double taxation on income and estate taxes. This Convention was amended by two amendments, from 2 October 1991 to 18 February 2011.
This agreement was concluded for five years from the date of its entry into force, with the possibility, opened by Article 20, paragraph 3, of a five-year extension by exchange of diplomatic notes.
Entry into force on 1 March 1983 and reappointed five times by an exchange of letters of 20 December 1988 and 22 February 1989, of 3 January 1994 and 3 May 1995, of 9 September 1998 and 2 January 1999, of 14 April and 6 July 2003, and of 27 November and 30 December 2008, the convention expires on 31 December 2013.
I have the honour of my Government to propose to you the extension of the convention of 18 February 1982 and the protocol annexed to it for a period of five years from 1 January 2014.
I would be grateful if you could let me know whether this proposal is a matter of your Government's approval. In this case, this letter, together with your answer, will constitute the agreement between our two Governments on the extension of the above-mentioned agreement, which will come into force on the date of your reply.
I pray, Your Royal Highness, to accept the assurance of my very high consideration.
Laurent Fabius
SAUDI ARABY ROYAUME
MINISTRY OF BUSINESS
N° 11/2/28/211070
Riyadh, 25 May 2014
The Ministry of Foreign Affairs presents its compliments to the French Embassy and refers to its note No. 13/2013 of 7/3/1435 H to which was attached the letter addressed by the French Minister for Foreign Affairs to SAR the Saudi Minister for Foreign Affairs and by which the French party expressed the wish to renew for five years the agreement signed by the governments of Saudi Arabia and France with a view to avoiding double taxation regarding tax on income, inheritance and fortune.
Pursuant to Article 20, paragraph 3, of the Convention, this Agreement shall remain in force until the end of the fifth year following the date of its entry into force. It may, however, be renewed by five years after agreement between States by exchange of diplomatic notes.
Accordingly, the Department wishes to inform the Embassy of the Saudi Party's agreement to renew the agreement and to amend the agreement for a period of five years beginning January 1, 2014.
The ministry takes this opportunity to renew the assurances of its high consideration.
Done on September 11, 2014.
François Hollande
By the President of the Republic:
The Prime Minister,
Manuel Valls
Minister for Foreign Affairs and International Development,
Laurent Fabius
