OrbitaxFrench Supreme Court Rules Eligibility for Parent-Subsidiary Directive Correctly Made Conditional on Beneficial Ownership
|Approved Changes|France
On 5 June 2020, the French Supreme Administrative Court (Conseil d'Etat) issued its decisions in four cases regarding eligibility for the dividend withholding tax exemption under the Parent-Subsidiary Directive (PSD). The PSD provides, inter alia, for a withholding tax exemption for profit distributions made by qualifying EU subsidiaries to their qualifying EU parents.
The directive specifies…
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