In a Parliamentary Response of 4 July 2006, the French Ministry of Finance stated that a Luxembourg sociétés d'investissement en capital à risque (SICARs) could not benefit from the reduced withholding tax rate under the France-Luxembourg tax treaty and from the exemption from dividend withholding tax under the EC Parent-Subsidiary Directive ((90/435/EEC). According to the Ministry, SICARs would only be eligible to the application of the reduced rates set out in Arts. 8, 9 and 10 of the France-Luxembourg tax treaty insofar it could be established that the income was effectively subject to tax in Luxembourg. Similarly, the exemption from...