The French Supreme Court (Conseil d'Etat) issued a decision on 5 July 2022 in a case concerning the 95% participation exemption for dividends received, which is increased to 99% if certain conditions are met. Under the participation exemption regime, the taxable 5% (1%) proportion (add-back) represents non-deductible costs related to the participation. As per guidance issued in March 2021 (BOI-IS-BASE-10-10-20), the tax authority stated that this add-back cannot be considered as leading to the partial taxation of dividends under the participation exemption regime. This statement is made in paragraph 100 of the guidance, which also provides that the add-back is...