France: Originals of Attestations 2779 or 2777 required by the French tax authorities
Clearstream Banking1 informs customers of stricter controls applied by the French Tax Authorities (FTA) on Attestations 2779 or 2777 provided to them in the frame of a reclaim of withholding tax.
Effective
immediately
only originals of the attestations are accepted by the FTA.
Background
Clearstream Banking AG2 (CBF) and when applicable, its local depository BNP Paribas Securities Services in their role of withholding tax agents, will provide Attestations 2779 or 2777 to the customers requesting to file a reclaim to the FTA. The updated procedure to request such attestations was recently published in Announcements C21054 and A21133.
In a recent communication to CBF, the FTA informed that they have noticed an increased number of requests filed to them using only copies of Attestations 2779 or 2777. To ensure a proper treatment and avoid duplicate refunds being granted, the FTA informed that only originals can be accepted for each reclaim of tax by Double Taxation Treaties’ (DTT) residents or exemption for foreign collective investment funds (CIVs).
The FTA have also informed their interlocutors such as lawyers, intermediary banks and other companies filing reclaims of such strict practice.
Impact on customers
CBF always provide an original Attestation 2779 for each request made by its customers.
Attestation 2777 provided by BNP Paribas Securities Services, usually in original version, is mailed to the customer.
It is the entire responsibility of the customers and beneficial owners to ensure that they use only original versions when filing reclaims to the FTA.
Clearstream Banking cannot be held responsible for any rejection by the FTA due to the use of copies of the original attestations provided by CBF or BNP Paribas Securities Services.
Further information
For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.
2. Clearstream Banking AG (CBF) refers to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.