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France Publishes Ruling on the Impact of Brexit on the 99% Participation Exemption for Dividends Received from UK

12 March 2019

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Approved Changes

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France-United Kingdom

France has published Ruling BOI-RES-000035-20190306 in the Official Gazette, which explains the application of the French 99% participation exemption for group dividends in relation to the UK leaving the EU. The ruling includes that after the UK leaves the EU/EEA, dividends received by French companies from UK companies will no longer be eligible for the 99% participation exemption for groups because UK companies will no longer meet the condition of being a "European Company". However, it will be considered that the condition is still met until the end of the year in which the UK leaves the EU. This is...