France: Finance Bill for 2019 - update
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.
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