The French Supreme Administrative Court on 20 July 2021 issued its decision on the application of withholding tax on dividends paid to a Belgian parent company in a situation where the latter temporarily transferred the shares in the French subsidiary to a Dutch administration office in a "stock certification" transaction. Under the French implementation of the parent-subsidiary directive, there is no withholding tax on dividends paid by a French subsidiary to its EU parent company on condition that the parent has held an interest of at least 10% in the distributing entity for at least 2 years. The minimum holding...