French Supreme Administrative Court Holds Withholding Tax on Capital Gains Derived by Italian Company on Sale of French Shares to be Fully Refunded

On 14 October 2020, the French Supreme Administrative Court (Conseil d'Etat) issued its decision in a case concerning withholding tax on capital gains derived from the sale of shares held by a non-resident in a French resident company. In general, where a non-resident company holds more than 25% of the rights to profits of a French company at any time in the five years preceding a sale, the ca…
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