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