MoF Answerback No 1152/S2 dated October 2, 2019 on mode of taxation of retirement pension payable in France to a Lebanese retired resident.

In compliance with the regulated tax inquiries as per the provisions of article 26 of the Law No 44/2008 on Tax Procedures and article 23 of its implementation decree No 2488 dated 29/05/2009, the Ministry of Finance (MoF) has issued an Answerback No 1152/S2 dated October 2, 2019 (here below) tackling the mode of taxation of retirement pensions payable in France. Thus, The Ministry responded by considering that, in accordance with the provisions of the double taxation treaty (DTT) signed by and between France and Lebanon and without prejudice to the provisions of article 20 of the said DTT, retirement pensions will only be liable to tax in the country in which the retired person is residing. However and since the Lebanese tax laws consider, by virtue of article 46 of the Income Tax Law (Legislative-decree No 144 dated 12/6/1959 and its amendments), that the tax on wages, salaries & retirement pensions apply on revenues derived in Lebanon only (territoriality principle), consequently the retirement pension payable in France as regards to activity implemented there where is not liable to tax in Lebanon as falling outside the territoriality principle.

 

Download (PDF, 248KB)