France - The New French 3% Withholding Tax on Profit Distributions: A Minefield for the French Government
- E. Robert
- European Taxation, 2013 (Volume 53), No 2/3
- 15 January 2013
In this note, the author discusses the new French corporate income tax surcharge, which was introduced as a response to the abolition of the French withholding tax on outbound dividends paid to non-resident UCITS. In particular, the note discusses the rules of the surcharge, various loopholes and discrepancies in regard to the provision and its compatibility with EU law.