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CJEU Rules on French Tax Credit for Tax Withheld on Dividends Paid from Other EU Member States

26 February 2021

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Treaty Development

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European Union-France-Italy-Netherlands-United Kingdom

On 25 February 2021, the Court of Justice of the European Union issued its judgment in a case concerning tax credits provided in France with respect to dividend income on which tax was withheld in other EU Member States. The case involved SGAM Banque, established in France, which is part of the tax-integrated group parented by Société Générale, also established in France. In the years ended 2004 and 2005, SGAM Banque received dividends less withholding tax paid on the dividends in respect of securities held by companies resident in Italy, the Netherlands, and the United Kingdom. In its return for...