French Court of Appeal Holds Dividends Received from Chile Not Eligible for Neutralization of Taxable Add-Back Under Parent-Subsidiary Regime
A recent decision of the Administrative Court of Appeal of Paris has been published on whether dividends received in 2015 by a French company from a wholly-owned subsidiary in Chile qualify for the neutralization of the taxable 5% add-back that represents non-deductible costs related to a participation when receiving dividends under the French parent-subsidiary regime. While it has been settle…
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