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Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published

29 July 2007

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Approved Changes

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France-EU-Iceland-Norway

The French tax administration published a second Guideline on 12 July 2007 (4 C-8-07), which lays down the procedural aspects pertaining to the exemption from French withholding tax on dividends paid by French companies to EEA parent companies, following the ECJ decision in Case C- 170/05  Denkavit delivered on 14 December 2006. The tax administration set out the main principles pertaining to the withholding tax exemption in Guideline 4 C-7-07 of 10 May 2007. Details of the second Guideline are summarized below. Background On 14 December 2006, the European Court of Justice (ECJ) gave its decision in the case Denkavit...