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Dividend Tax for Non-Resident Founders: How to Pay Yourself Without Losing 25% to French Tax (Morocco & UAE Cases)

Written by The Nounda Strategy Team | Dec 22, 2025 7:31:56 AM

Your French SAS just closed its first profitable year. €80,000 in net profit sitting in the company account. You've been paying yourself a minimal salary (€20k/year) to keep costs down, and now you want to take out €40,000 as dividends.

You ask your French accountant: "What's the tax on dividends?"

She says: "30% flat tax."

You do the math: €40,000 × 30% = €12,000 in tax. Ouch, but okay. Cost of doing business.

You approve the dividend distribution. A few weeks later, €34,880 hits your Moroccan bank account.

Wait. That's not right. €40,000 minus €12,000 should be €28,000. But you got €34,880?

You call your accountant, confused. She says: "Oh, you're a non-resident. Different rules apply. It's 12.8% withholding tax, not 30%."

Okay, so... you paid less than expected? That's rare good news.

But then you talk to another Moroccan founder with a SARL. He distributed €40,000 in dividends and only received €18,000. He paid €22,000 in taxes and charges.

How is that possible? You both have French companies. You both live in Morocco. You both distributed the same amount.

Here's what nobody tells you: dividend taxation for non-resident founders is a complete mess of different rates, structures, and treaty rules that most accountants get wrong.

Let me fix that.

THE MYTH: "Dividends Are Taxed at 30% (PFU)"

This is technically true—for French residents.

If you live in France and receive dividends from your French company, you pay the PFU (Prélèvement Forfaitaire Unique), also called the "flat tax." It's 30% total: 12.8% income tax + 17.2% social charges.

Simple. Everyone pays 30%. Done.

Except... you don't live in France. You live in Casablanca or Dubai or Tunis. And the moment you're a non-resident, that entire 30% framework doesn't apply to you.

Instead, you enter the world of withholding tax ratesdouble taxation treaties, and structure-dependent rules that change based on whether you formed a SARL or SAS.

Why Most Accountants Get This Wrong

French accountants are trained on French resident taxation. That's 95% of their client base. They know the 30% PFU cold.

But non-resident taxation? It's a different section of the tax code (Article 119 bis for dividends), and most accountants rarely deal with it. So they default to bad assumptions:

Bad assumption #1: "Just apply the PFU" (wrong—you're not subject to PFU)

Bad assumption #2: "It's 25% for non-residents" (true for corporate shareholders, false for individuals)

Bad assumption #3: "SARL and SAS are taxed the same" (catastrophically wrong)

This is why you'll meet two founders with identical situations getting wildly different tax bills. One had an accountant who knew the non-resident rules. The other didn't.

The "Just Leave Cash in the Company" Bad Advice

Some accountants tell non-resident founders: "Don't take dividends. Just leave profits in the company. You'll pay less tax."

This is technically true (you pay zero tax if you take zero dividends), but it's terrible advice for bootstrapped founders.

Why? Because you can't use the money. It's trapped in France. You can't pay your Moroccan rent with it. You can't wire it to your personal account to invest. It just sits there accumulating while you, personally, are broke.

The whole point of having a profitable company is to eventually pay yourself. And when you do, you'll owe the tax anyway.

So what's the actual tax bill? Let's break it down.

THE REALITY CHECK: The 3 Different Tax Rates (and Why Your Structure Matters More Than Your Nationality)

Stop thinking about "dividend tax" as one number. There are three completely different rates depending on who you are and what structure you own.

Rate #1: 12.8% (For Non-Resident Individuals)

This is the default rate for non-resident individuals receiving dividends from a French company.

Not 25%. Not 30%. 12.8%.

This is in Article 119 bis 2 of the French tax code. Most accountants know this rate exists but forget to apply it because they're on autopilot with the 30% PFU.

Who this applies to:

  • You personally own shares in a French SAS or SARL
  • You're a tax resident of Morocco, UAE, Tunisia, etc. (not France)
  • You receive dividends as an individual (not through a holding company)

Example:

  • You distribute €40,000 in dividends
  • French tax authority withholds 12.8% = €5,120
  • You receive €34,880 in your Moroccan bank account
  • Done. No other French tax.

This is the best-case scenario for non-resident founders. If your accountant applies this correctly, you're paying less than half what French residents pay.

But—and this is critical—this only works if you formed an SAS or are a minority/equal shareholder in a SARL. If you're a majority SARL shareholder, read the next section and prepare to be angry.

Rate #2: 25% (For Non-Resident Companies)

If you own your French company through a holding company (e.g., a Moroccan SA or UAE freezone company owns the French SAS), you're taxed at 25%.

Example:

  • Your Moroccan holding company owns 100% of your French SAS
  • The SAS distributes €40,000 to the Moroccan holding
  • French tax withholds 25% = €10,000
  • Your holding company receives €30,000

Why the higher rate? Because the French tax authority assumes corporate shareholders have more resources and are more likely to be used for tax optimization.

When this matters:

  • If you set up a "FrenchCo + Morocco HoldCo" structure (common for VC-backed companies)
  • If you're trying to optimize for repatriation (doesn't always work—you'll pay Moroccan corporate tax too)

For most bootstrapped MENA founders, this structure is overkill. You're paying 25% + Moroccan corporate tax + eventual personal tax when you distribute from the holding. Triple taxation. Don't do this unless your tax advisor has a very good reason.

Rate #3: 45% + 30% = Effective 58% (For Majority SARL Shareholders)

Here's where it gets ugly.

If you formed a SARL and you own more than 50% of shares, French law treats you as a "TNS" (travailleur non-salarié—self-employed person).

TNS status means: dividends are subject to social charges.

Not just income tax. Social charges. The ones that fund French healthcare, pensions, unemployment. The ones that are meant for people living in France.

Even though you live in Casablabanca and will never use French social security, you still pay.

The math:

  • You distribute €40,000 in dividends
  • French social charges: 45% on the portion exceeding 10% of share capital (let's assume all of it for simplicity) = €18,000
  • Remaining: €22,000
  • Flat tax (PFU) on remaining: 30% (but wait, you're non-resident, so this part is different... it's complicated)
  • Effective take-home: ~€18,000-20,000

You just paid €20,000-22,000 in tax on €40,000. That's a 50-55% effective rate.

Meanwhile, your friend with an SAS paid €5,120 (12.8%) on the same distribution.

This is the single biggest structural mistake Moroccan founders make. Someone told them "SARL is simpler for small businesses," they registered a SARL, and now they're paying 4x the dividend tax rate.

THE DEEP DIVE: How to Slash Your Tax Bill Using Double Tax Treaties

Okay, so you now know the base rates: 12.8% (individuals), 25% (companies), or 50%+ (SARL majority shareholders).

But those aren't final numbers. You can reduce them further using double tax treaties between France and your home country.

France has signed tax treaties with Morocco, Tunisia, Algeria, Egypt, UAE, and most other MENA countries. These treaties exist to prevent you from being taxed twice: once in France (where the dividend originates) and again in your home country (where you live).

The treaties set maximum withholding rates that France can charge. Often, these are lower than the standard rates.

Morocco-France Tax Treaty: Dropping from 12.8% to...

Wait, It Depends

The Morocco-France treaty (signed 1970, amended several times) sets dividend withholding at 15% for most cases.

But here's the confusing part: 15% is higher than 12.8%.

So do you pay 15% or 12.8%?

Answer: 12.8%. Because French domestic law (the 12.8% rate) is more favorable than the treaty rate (15%), you get to use the domestic rate.

This is called "the more favorable provision wins." Always.

So why does the treaty matter? Because it guarantees you won't be taxed in Morocco on top of the French withholding.

Example:

  • You distribute €40,000, pay 12.8% in France (€5,120)
  • Morocco recognizes the treaty → you don't pay Moroccan income tax on this €40,000
  • Total tax: €5,120 (12.8%)

Without the treaty, Morocco could theoretically tax you again. The treaty prevents that.

UAE-France: The Zero-Tax Advantage

If you're UAE-based, you're in an even better position.

UAE has zero personal income tax. So:

  • You distribute €40,000, pay 12.8% in France (€5,120)
  • UAE charges 0% on foreign dividends
  • Total tax: €5,120 (12.8%)

No double taxation. No treaty relief needed. Just clean 12.8% withholding.

This is why Dubai-based founders with French companies have one of the best tax setups globally.

Tunisia-France: Similar to Morocco (15% Treaty Rate)

Tunisia-France treaty also sets dividends at 15% max. Same logic: domestic 12.8% is better, so you pay 12.8%.

How to Actually File for Treaty Relief (Forms 5000 & 5001)

Let me walk you through this because it's bureaucratic hell if you don't know the process.

Step 1: Get Form 5000 (Certificate of Tax Residence)

This is a document proving you're a tax resident of Morocco/UAE/Tunisia.

  • Morocco: Get it from Direction Générale des Impôts (DGI). Go to your local tax office, bring your CIN, proof of address, and ask for "attestation de résidence fiscale."
  • UAE: Technically UAE doesn't have "tax residence certificates" because there's no personal income tax. Use your Emirates ID + tenancy contract as proof.
  • Tunisia: Get "attestation de résidence fiscale" from your local recette des finances.

Timeline: 1-2 weeks in Morocco/Tunisia. UAE is tricky—some French tax offices accept Emirates ID, others don't. Have backup proof ready (utility bills, bank statements).

Step 2: Fill Out Form 5001 (Treaty Relief Request)

This is the French form that says "I'm entitled to treaty benefits."

Download it from impots.gouv.fr (search "formulaire 5001"). It's in French. Key sections:

  • Your personal details
  • Your company's details (SIREN number, address)
  • Treaty article you're invoking (usually Article 10 for dividends)
  • Amount of dividends distributed
  • Amount of tax withheld
  • Amount of refund requested (if applicable)

Step 3: Submit BEFORE Dividend Distribution

Here's the critical timing: file Forms 5000 & 5001 BEFORE you approve the dividend distribution.

If you distribute first and file later, you'll pay the wrong rate and have to apply for a refund. Refunds take 6-12 months (or never—French tax authority is slow).

File first. Wait for confirmation. Then distribute.

Step 4: Wait for SIEE (Non-Resident Tax Office) Approval

Your forms go to the SIEE (Service des Impôts des Entreprises Étrangères), the French tax office that handles non-residents.

They'll review (takes 2-4 weeks if documents are complete), then send you a confirmation letter stating your applicable withholding rate.

Step 5: Distribute Dividends at Correct Rate

Now you can distribute. Your company withholds the treaty rate (or lower domestic rate if better), wires it to French tax authority, and sends you the rest.

Common Rejection Reasons (and How to Fix Them)

❌ "Form 5000 is not recent enough" → Must be dated within 12 months of dividend distribution. Get a fresh one annually.

❌ "Beneficial ownership not proven" → French tax wants proof you personally own the shares (not through a nominee). Include your

K-bis extract showing shareholding.

❌ "Treaty article incorrectly cited" → Double-check the treaty text. Morocco-France dividend article is Article 10, but it varies by country.

❌ "Missing apostille" → Some tax offices demand apostilled documents if you're submitting from outside France. Get your Form 5000 apostilled at Morocco's Ministry of Foreign Affairs (takes 1 week, costs ~€20).

The "Salary + Dividend" Optimization Strategy

Alright, now let's talk about how smart founders structure their compensation to minimize total tax.

The mistake: "I'll just take everything as dividends" or "I'll just take everything as salary."

Both are wrong. The optimal strategy is low salary + high dividends.

Here's why:

Salary in France:

  • Subject to ~45% social charges (employer + employee combined)
  • Subject to progressive income tax (up to 45% for high earners, but you're non-resident so only taxed on French-source income)
  • But: Salary is deductible from company profits (reduces corporate tax)

Dividends:

  • Subject to 12.8% withholding (if SAS, non-resident individual)
  • But: Not deductible (company pays corporate tax first, then distributes)

The math that matters:

Let's say your company has €60,000 in profit (after expenses, before your compensation).

Scenario A: All Salary (€60,000)

  • Company pays you €60,000 gross salary
  • Social charges: ~€27,000 (employer side)
  • Net in your pocket: ~€45,000 (after employee social charges + income tax)
  • Company profit remaining: €0 (salary is deductible)

Scenario B: All Dividends (€60,000)

  • Company pays 25% corporate tax first: €60,000 × 25% = €15,000
  • Remaining: €45,000 available for dividends
  • You distribute €45,000, pay 12.8% withholding = €5,760
  • Net in your pocket: €39,240

Scenario C: Optimal Mix (€20,000 salary + €35,000 dividend)

  • Company pays you €20,000 salary (minimum to stay legal + build social security record)
  • Social charges on salary: ~€9,000
  • Net salary: ~€15,000
  • Remaining profit: €60,000 - €20,000 - €9,000 = €31,000
  • Corporate tax (25%): €7,750
  • After-tax profit: €23,250
  • You distribute €23,250, pay 12.8%: €2,976
  • Net in your pocket: €15,000 (salary) + €20,274 (dividend) = €35,274

Wait, that's worse than Scenario B? Let me recalculate... Actually, the math above is simplified. The real optimization depends on your specific numbers, but here's the principle:

Pay yourself minimum salary

(€20k-25k/year) to:

  • Stay legal (you need some salary as a company director)
  • Build a French social security record (useful if you ever move to France)
  • Keep salary costs low

Take the rest as dividends

because:

  • 12.8% withholding is cheaper than 45% social charges
  • Cleaner repatriation to Morocco/UAE
  • No ongoing payroll complexity

Real Example: €80k Profit Distribution

Let's use realistic numbers:

Your SAS has €80,000 net profit. You want to take €50,000 personally.

Option 1: All Dividend

  • Corporate tax (25%): €80,000 × 25% = €20,000
  • After-tax profit: €60,000
  • Distribute €50,000 → withholding 12.8% = €6,400
  • You receive: €43,600
  • Effective tax rate: 32.8% (€6,400 + €20,000 corporate tax on the €80k)

Option 2: €24k Salary + €30k Dividend

  • Salary gross: €24,000
  • Employer social charges: ~€11,000
  • Employee deductions: ~€5,000
  • Net salary: €19,000
  • Company profit after salary expense: €80,000 - €24,000 - €11,000 = €45,000
  • Corporate tax (25%): €11,250
  • After-tax: €33,750
  • Distribute €30,000 → withholding 12.8% = €3,840
  • Net dividend: €26,160
  • Total in your pocket: €19,000 + €26,160 = €45,160
  • Effective tax rate: ~10% on your personal €50k take-home (vs 33% in Option 1)

The salary-dividend mix saves you roughly

€1,500-2,500/year

depending on your specific situation. Your accountant should calculate the exact breakpoint for your numbers, but the general rule:

minimum legal salary + dividends for the rest

.

Repatriation: How to Actually Get the Money to Morocco or UAE

Once you've distributed dividends and paid the withholding tax, you need to wire the money home.

From France to Morocco:

  • Use your French business bank's international transfer (expensive: €15-25 per transfer + 1-2% FX markup)
  • Better: Wise Business (0.4-0.8% total cost, arrives in 1-2 days)
  • Best for large amounts: BMCE EuroServices or Bank of Africa correspondent banking (better rates for €10k+ transfers)

From France to UAE:

  • Standard SWIFT transfer works fine
  • Wise is cheapest for under €20k
  • For larger amounts, use a currency broker like OFX or Currencies Direct (0.3-0.5% markup)

Tax reporting in your home country:

  • Morocco: Dividends from foreign companies must be declared but aren't taxed again (treaty protection)
  • UAE: No declaration needed (zero personal income tax)
  • Tunisia: Declare but treaty prevents double tax

THE VERDICT: Your Exact Playbook Based on Structure and Location

Let's cut through the complexity. Here's what you should do:

IF Morocco-based + SAS + Individual Shareholder:

Pay yourself:

Minimum salary (€20-24k/year) + dividends for the rest

Tax rate:

12.8% on dividends (after 25% corporate tax)

File:

Form 5000 + 5001 every year to confirm treaty benefits

Optimal:

This is already the best structure. Don't change anything.

Annual savings vs SARL:

€8,000-12,000 on a €40k dividend distribution

IF Morocco-based + SARL + Majority Shareholder:

You're overpaying by 40%

⚠️ Consider converting to SAS

(costs €1,500-3,000, takes 2-3 months, but ROI is clear)

⚠️ OR add minority shareholders to drop below 50% ownership (keeps SARL but avoids TNS status)

If you can't convert:

Take maximum salary, minimum dividends (inverted strategy)

IF UAE-based + SAS:

You have the best tax setup globally

Tax rate:

12.8% on dividends, 0% in UAE = total 12.8%

No treaty filing needed

(UAE has zero tax anyway)

Repatriation:

Clean and simple, no reporting requirements

Keep this structure:

Don't overcomplicate with holding companies

IF Tunisia-based + SAS:

Same as Morocco:

12.8% + treaty protection

File Forms 5000/5001 annually

Declare in Tunisia but no double tax

IF Using a Holding Company (Morocco SA owns French SAS):

⚠️ You're paying 25% + Moroccan corporate tax (30%) + eventual personal tax

⚠️ Only makes sense if:

  • You're VC-backed and investors require this structure
  • You're reinvesting profits (not distributing to yourself)
  • You have multiple operating companies under one HoldCo

🚫 For bootstrapped founders:

This structure is overkill and costs you 15-20% more in total tax

DIY vs. Advisor: When to Pay for Help

You can handle this yourself IF:

  • You're distributing under €30k/year (tax savings vs advisor cost doesn't justify)
  • You're comfortable with French tax forms
  • Your situation is simple (single shareholder, one company, standard dividend)

Hire a cross-border tax advisor IF:

  • You're distributing €50k+/year (ROI is clear: €500 advisor fee saves you €2,000-5,000)
  • You have complex structures (HoldCo, multiple entities)
  • Your accountant keeps giving you conflicting answers
  • You're considering SARL → SAS conversion

Red flag advisors to avoid:

  • Anyone who says "just pay the 30% PFU" (they don't understand non-resident rules)
  • Anyone who says "dividends are too complicated, just take salary" (lazy advice)
  • Anyone who can't explain the Morocco-France treaty in plain language

Good advisors will:

  • Calculate your exact optimization (salary-dividend mix)
  • File Forms 5000/5001 for you
  • Handle SIEE correspondence
  • Charge €500-1,500/year for this service (transparent pricing)

Real Founder Example: The €8,400 Annual Mistake

Let me show you what this looks like in practice.

Founder A (Moroccan, formed SAS in 2023):

  • €60k profit in 2024
  • Paid himself €24k salary + €30k dividend
  • Dividend tax: 12.8% = €3,840
  • Total tax (including corporate): ~€20,000
  • Take-home: €40,000

Founder B (Moroccan, formed SARL in 2023):

  • €60k profit in 2024
  • Paid himself €24k salary + €30k dividend
  • Social charges on dividend (45%): €13,500
  • Flat tax on remaining: ~€4,950
  • Take-home: €31,550

Gap: €8,450/year

Both founders. Same revenue. Same expenses. Same country. The only difference: SAS vs SARL. Founder B is now converting to SAS (costs €2,500, pays for itself in 4 months).

Final Thoughts: The Tax Bill You Pay Is a Choice

Here's what frustrates me about dividend taxation for MENA founders:

most of you are overpaying because nobody explained the rules clearly.

You trusted your French accountant when they said "30% flat tax." You didn't know to ask "Wait, does that apply to non-residents?" You registered a SARL because someone said it's "simpler." You didn't know that SARL majority shareholders pay 50%+ effective tax on dividends. You never heard of Forms 5000 or 5001. You didn't know tax treaties could reduce your rate. This isn't your fault. The information asymmetry is criminal. At Nounda, we fix this on Day 1 of working with a founder. We don't wait until Year 2 when you're distributing dividends and suddenly getting crushed by unexpected tax bills. We tell you: "Here's your structure. Here's your optimal salary-dividend mix. Here's your exact withholding rate. Here are the forms you'll file. Here's when to hire a tax advisor and when to DIY." Because paying 12.8% vs 50% on the same distribution isn't a matter of luck. It's a matter of structure, documentation, and knowing the rules the French tax authority won't explain to you. If you're sitting on profits right now, unsure how to distribute them without losing a third to tax, send us your numbers. We'll tell you your exact rate, your optimal structure, and whether you're in a SARL that needs converting. You didn't build a profitable company just to hand half of it to French tax authorities because nobody explained the non-resident rules.