The French Supreme Court (Conseil d'Etat) on 20 May 2022 issued its decision in a case concerning the payment of royalties by a French company, "Planet", through interposed Belgian and Maltese recipients towards the use of intangibles developed by a company established in New Zealand. The tax authorities denied the application of the benefits under the treaties with Belgium and Malta on the grounds that the recipients in the respective jurisdictions were mere intermediaries and not the beneficial owners of the income. Instead, the tax authorities applied the 10% withholding tax under the France-New Zealand tax treaty. In the subsequent...