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To embed, copy and paste the code into your website or blog: The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant with EU law. IN DEPTH Background Under the French participation exemption regime, the capital gain realized by a French parent company subject to French corporate tax upon the sale of a qualifying shareholding is exempt from taxation, subject to the inclusion of a lump sum representing 12% of the capital gain (which makes for an 88% exemption). This 12% inclusion does not constitute a partial taxation of the capital gain, but a way to recapture past deductible expenses in relation to the qualifying shareholding.

United arab emiratesÎe de franceNew zealandSaudi arabiaSouth koreaFrench supreme tax court conseilRuna capital fundFrench supreme tax courtDecision of the french supreme tax courtVersailles courtInternational holdingMcdermott willFrench supreme taxஒன்றுபட்டது அரபு அமீரகங்கள்புதியது ஜீலாந்துசவுதி அரேபியா