Market Taxation Guide - France (securities held in CBF)

04.02.2021

This Market Taxation Guide (France) provides the following details:

  • Reference information about all taxes applied at source through Clearstream Banking1 to securities deposited in CBF; and
  • Instructions for obtaining relief at source or a refund of withholding tax, where these are available, through Clearstream Banking.

New and improved tax information and procedures that become available will be included on an ongoing basis.

Important note:

This Market Taxation Guide (including any attachments and other links) is for informational purposes only and is not intended and should not be considered to be legal advice on any subject matter. Readers of this Market Taxation Guide, whether customers or otherwise, should not act or refrain from acting on the basis of any information included in this Market Taxation Guide without seeking appropriate legal or other professional advice.

Withholding tax

For debt securities:

  • Bonds issued before 1 January 1987 are taxed at 15%;
  • Bonds issued before 1 January 1965 are taxed at 17%.

No relief at source or reclaim of withholding tax on French debt securities is available through Clearstream Banking.

EquitiesHolding restriction?Withholding tax rateRelief at
source
Quick
refund
Standard
refund

No

26.5%a

Residents of Double Taxation Treaty (DTT) countries

Yes

Yes

Yes

Foreign individuals

Yes

Yes

Yes

Foreign Collective Investment Vehicles (CIVs)b

Yes

Yes

Yes

EU parent companiesc

Yes

Yes

Yes

Not-for-Profit Organisations

Yes

Yes

No

Foreign exempt entities

Yes

Yes

Yes

Particular foreign entities

Yes

Yes

Yes

French residents (direct customers)

Yes

Yes

No

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a. 30% until 31 December 2019, 28% until 31 December 2020 and  26.5% as of 1 January 2021.
b. Special treatment applies to non-EU CIVs. Refer to section Relief at Source and Standard Refund of this tax guide. 
c. EU companies holding a substantial participation in the capital of the French company that is paying the dividend.

Capital gains tax

There is no capital gains tax withheld through Clearstream Banking on securities held in Clearstream Banking. Capital gains tax may however be payable on specific gains. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.

Stamp Duty

There is no stamp duty withheld through Clearstream Banking on securities held in Clearstream Banking. Stamp duty may however be payable on specific transactions. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.