A recent decision of the Administrative Court of Appeal of Paris has been published on whether a French parent company should be entitled to deduct (neutralize) the taxable 5% add-back that represents non-deductible costs related to a participation when receiving dividends, if not a parent of an integrated tax group. The case involved a French company that received dividends in 2012 and 2014 from its Belgian subsidiary, which was 99.99% owned. The company deducted the dividends received and further requested a refund for the deduction of the 5% add-back, which was denied by the tax authority because the French company...