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French Constitutional Court Holds Previous Neutralization of the 5% Add-Back on Dividends under the Participation Exemption is Constitutional

|Approved Changes|France
France

The French Constitutional Court (Conseil Constitutionnel) recently issued a decision on whether the previously allowed deduction (neutralization) of the taxable 5% proportion (add-back) for costs and expenses under the French participation exemption regime for qualifying dividends was in line with the constitutional principle of equality. The neutralization of the 5% add-back was abolished fro…

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