The New French 3% Withholding Tax on Profit Distributions: A Minefield for the French Government

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.