France-Greece tax convention 1963 vs 2022: comparative guide

On 11 May 2022, France and Greece signed a new bilateral tax convention, published on the French side by Decree no. 2024-16 of 11 January 2024 (JORFTEXT000048898913). It entered into force on 30 December 2023 and applies to income received from 1 January 2024 onwards. It replaces the historical convention of 21 August 1963.

This article (currently available in French only) provides a full comparative guide of the 2022 convention versus the 1963 convention, with a focus on practical consequences for French property owners in Greece: rental income, capital gains on sale, foreign bank accounts, and the new automatic exchange of tax information.

Key points for French property owners

• Article 6 (immovable property income): rental income from a Greek property is taxed in Greece, France eliminates double taxation via tax credit under Article 21.
• Article 13 (capital gains): capital gains from the sale of immovable property situated in Greece are taxable in Greece.
• Article 20 (other income): new catch-all clause for income not explicitly covered by Articles 6 to 19.
• Article 21 (elimination of double taxation): France applies a limited tax credit method.
• Automatic exchange of bank information: French and Greek tax administrations now exchange data automatically. Undeclared Greek bank accounts should be regularised proactively.

For a complete walkthrough including practical case studies, comparative tables, and the calendar of application, please read the full French version of this article.