Stylist, withholding tax, and the Franco-Israeli tax treaty

A fashion designer living in Israel had provided services to a Parisian haute couture house. The house had paid him by withholding 10% at source, which it then remitted to the tax authorities.

The designer then requested a refund of this withholding tax fromadministration .

The Administrative Court of Appeals, to which the case was referred, first ruled that, contrary to the designer’s claim, the consulting and design contracts entered into with the haute couture house did not establish that he was an employee of the house.

Thus, under domestic law, Article 182 B of the General Tax Code was indeed applicable.

The court will then rule that the income paid was indeed received in connection with self-employment within the meaning of Article 14 of the treaty between France and Israel, and not in connection with employment as claimed byadministration .

She also notes that the designer did not have a permanent place of business in France and that he stayed there for fewer than 183 days.

Under these circumstances, it considers that Article 14 of the Franco-Israeli tax treaty did indeed preclude the application of the withholding tax.

The court therefore orders the reimbursement of the latter.

CAA Paris, May 18, 2026, No. 24PA04140

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