France: Finance Bill for 2019 - update

02.01.2019

The French National Assembly has recently adopted an amendment to the proposed Finance Bill previously adopted by the French Senate for the purpose of fighting against dividend arbitrage transactions (cum/cum transactions). This is further to our Taxflash T18039.

Under the amendments proposed by the French National Assembly, the first measure aiming at applying a taxation of certain cash flows corresponding indirectly to a retrocession of dividend (dividend equivalent, manufactured dividends) to a non-resident shareholders, if definitely approved by the French Parliament, will be effective on 1 July 2019.

Please note that the second measure proposed by the French Senate and targeting schemes aiming at taking advantage of a tax exemption under a double taxation treaty is no longer included in the amended Bill.

We will continue to monitor the situation and will provide further information as it becomes available.

This Taxflash is intended to provide customers with general information gathered from different sources that are generally believed to be reliable. Clearstream Banking S.A. does not guarantee the accuracy or completeness of the information and does not undertake to keep it up to date. Use of the information made available in this Taxflash is at the customer’s own risk and Clearstream Banking S.A., its subsidiaries and affiliates expressly disclaim any liability for any errors or omissions reflected herein. The information in this Taxflash does not constitute legal or tax advice.