Market Taxation Guide - France

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

Reference information about all taxes applied at source, to investment funds securities held with the CSD and deposited in CEU through Clearstream Fund Centre (Vestima Fund Securities); and

Instructions for obtaining a refund of withholding tax, where these are available, through Clearstream Fund Centre.

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 clients 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 services

For Vestima fund securities (ETFs): deposited in CEU through Clearstream Fund Centre;

ETFs	Holding restriction?	Withholding tax rate	Relief at source	Quick refund	Standard refund
	No	25%
Residents of Double Taxation Treaty (DTT) countries			No	No	Yes
Foreign individuals			No	No	Yes
Foreign Collective Investment Vehicles (CIVs)^b			No	No	Yes
EU parent companies^c			No	No	Yes
Not-for-Profit Organisations			No	No	No
Foreign exempt entities			No	No	Yes
Particular foreign entities			No	No	Yes
French residents (direct clients)			No	No	No

Other UCITs Investment funds – excluding ETFs	Holding restriction?	Withholding tax rate	Relief at source	Quick refund	Standard refund
	No	25%
Residents of Double Taxation Treaty (DTT) countries			No	No	Yes
Foreign individuals			No	No	Yes
Foreign Collective Investment Vehicles (CIVs)^a			No	No	Yes
EU parent companies^c			No	No	Yes
Not-for-Profit Organisations			No	No	No
Foreign exempt entities			No	No	Yes
Particular foreign entities			No	No	Yes
French residents (direct clients)			No	No	No

a. Special treatment applies to non-EU CIVs. Refer to section 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 Fund Centre on Vestima fund securities held in Clearstream Fund Centre. Capital gains tax may however be payable on specific gains. Clearstream Fund Centre does not assist in this regard. Please consult your tax advisor for further information.

Stamp Duty

There is no stamp duty withheld through Clearstream Fund Centre on Vestima fund securities held in Clearstream Fund Centre. Clearstream Fund Centre does not assist in this regard. Please consult your tax advisor for further information.

Market Taxation Guide - France - CFCL