OrbitaxECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
|Approved Changes|European Union-France
On 3 April 2008, the European Court of Justice (ECJ) gave its decision in the case of Banque Féderative du Crédit Mutuel v. Ministre de l'Économie, des Finances et de l'Industrie (C-27/07). The French Administrative Supreme Court had requested a preliminary ruling from the ECJ on 17 January 2007.
The ECJ held that the concept of "profits distributed by the subsidiary", with…
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