France - French Foreign Tax Credit: A Clap of Thunder in a Calm Sky
- B. Boisanté
- Derivatives & Financial Instruments, 2016 (Volume 18), No 3
- 4 August 2016
Tax credits granted under French income tax treaties are generally limited to the “amount of French tax attributable to that income”. The common interpretation was that this amount corresponded to gross income multiplied by the standard tax rate. A recent decision of the Council of State (the supreme administrative court) marks an unfortunate turn for French recipients of foreign-source dividends.