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French Court of Appeal Rules on Claims for Foreign Tax Credit for Difference between Add-Back Under Participation Exemption and Actual Costs

|Approved Changes|France
France

A recent decision of the Administrative Court of Appeal of Paris has been published concerning the substantiation of claims for a tax credit in relation to dividends received under the 95% participation exemption in cases where the actual costs are less than the taxable 5% add-back that represents non-deductible costs related to a participation. As previously reported, the French Supreme Court…

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