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France Adds Hybrid-Mismatch Provisions to Amended Finance Bill for 2014

|Proposed Changes|France
France

As parliamentary discussions continue for France's Amended Finance Bill for 2014, provisions have been added to counter hybrid-mismatch arrangements resulting in double non-taxation. The provisions are in line with the amendment to the EU Parent-Subsidiary Directive adopted by the EU Council.

Under the provisions, the participation exemption for income from shares would be denied if:

  • The inco…

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