Article 20 of the 2022 convention: other income clause

Article 20 of the 2022 France-Greece tax convention introduces a catch-all clause for income not explicitly addressed by Articles 6 through 19 (real estate, business profits, dividends, interest, royalties, capital gains, employment, directors, artists, pensions, public service, students). Such income is taxable only in the State of residence of the recipient. This is a structural novelty compared to the 1963 convention, which left several categories in a legal grey zone.

For a French tax resident receiving Greek-source income that doesn't fit a specific category (digital platform earnings, exceptional indemnities, unclassifiable accessory income), Article 20 establishes that France alone has the right to tax. The mechanism prevents both double taxation and double non-taxation, closing the grey zones of the previous regime.

Practical example

Mr C., French tax resident owning a studio in Sitia, earns €800 from a Greek tourism platform affiliate programme in 2025. Under the 1963 convention, the qualification of these €800 would have been ambiguous. Under Article 20 of the 2022 convention, they fall clearly under France-only taxation, declared as occasional non-commercial profits (BNC) on French form 2042 C PRO.

Read the full French version for a detailed walkthrough including limits of Article 20, comparison with the 1963 convention, and FAQ on declaration mechanics.