TLDR: Only residents of Singapore are explicitly excluded from the simplified procedure for French-source dividends, due to the specific provisions set out in the France-Singapore tax treaty.
Confirmed exclusion
The simplified procedure, which allows automatic access to reduced rates or exemptions provided by double taxation treaties, does not apply to residents of Singapore. This exclusion is directly linked to Article 23 of the France-Singapore tax treaty of 9 September 1974, which provides for a separate procedure for the application of treaty benefits.
Legal basis
The exclusion is explicitly mentioned in the official French documentation (BOI-INT-DG-20-20-20-20-20120912). No other exclusion is formally identified for other states or entities in the sources analysed.
Scope of the exclusion
The exclusion applies only to residents of Singapore. No other exceptions have been confirmed for specific entities (UCITS, pension funds, etc.) or other states in the documents consulted.
Absence of other exclusions
The sources do not mention any other explicit exclusion for entities or states other than Singapore. Therefore, the simplified procedure remains applicable to all other residents of states that have concluded a tax treaty with France, unless otherwise provided in unidentified provisions.
Treaty context
The France-Singapore treaty imposes a specific procedure for the application of tax benefits, distinct from the standard simplified procedure. This justifies the specific exclusion of Singapore.
Analysis limitations
The available information is limited to official French sources. No other exclusions have been confirmed in the documents analysed.