Due to their total exemption from corporate income tax or their tax transparency, undertakings for collective investment (UCIs) are generally not considered as residents of France within the meaning of tax treaties. Unless specific provisions are made, UCIs do not therefore benefit from treaty advantages reducing withholding tax rates on dividends, interest and capital gains received from abroad. They are subject to withholding tax at the domestic rate provided by the States (generally 30%) instead of the conventional rates (0% to 15%).