France Administrative Court of Appeal of Paris Clarifies Withholding on Dividends Paid to Foreign Funds

The French Administrative Court of Appeal of Paris May 29 issued Decision No. 24PA03673, clarifying withholding tax on French-source dividends paid to foreign investment funds. The taxpayer, a Luxembourgish investment management company, acted on behalf of a related investment fund that it managed, and sought a refund of withholding tax on French dividends paid to entities affiliated with the fund. The taxpayer argued in part that an exemption applied because the foreign investment fund was comparable to a French undertaking for collective investment in transferable securities (UCITS). The Administrative Court of Montreuil denied the refund request with respect to certain ...