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French Court Rules Group Dividend Tax Rule for Integrated Groups Violates Freedom of Establishment for Non-Integrated Parent

|Approved Changes|France
France

A recent decision of the Administrative Court of Appeal of Paris has been published on whether a French parent company should be entitled to deduct (neutralize) the taxable 5% add-back that represents non-deductible costs related to a participation when receiving dividends, if not a parent of an integrated tax group. The case involved a French company that received dividends in 2012 and 2014 f…

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