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French Supreme Court Disallows Dividend Withholding Tax Exemption to Belgian Parent Company in Case of Temporary Share Transfer in "Stock Certification" Transaction

|Approved Changes|France-Belgium-Netherlands
France-Belgium-Netherlands

The French Supreme Administrative Court on 20 July 2021 issued its decision on the application of withholding tax on dividends paid to a Belgian parent company in a situation where the latter temporarily transferred the shares in the French subsidiary to a Dutch administration office in a "stock certification" transaction. Under the French implementation of the parent-subsidiary directive, ther…

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