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France Publishes Ruling on the Impact of Brexit on the 99% Participation Exemption for Dividends Received from UK

France has published Ruling BOI-RES-000035-20190306 in the Official Gazette, which explains the application of the French 99% participation exemption for group dividends in relation to the UK leaving the EU.

The ruling includes that after the UK leaves the EU/EEA, dividends received by French companies from UK companies will no longer be eligible for the 99% participation exemption for groups because UK companies will no longer meet the condition of being a "European Company". However, it will be considered that the condition is still met until the end of the year in which the UK leaves the EU. This is supposed to occur the end of March 2019, in which case dividends received from UK companies by French companies may qualify for the 99% exemption until 31 December 2019, provided that the conditions for the 99% exemption are met. The conditions include that the UK company would qualify to be a member of a French group if established in France, including a 95% ownership condition.

Note - The French 95% participation exemption, which requires 5% ownership, would continue to apply in respect of dividends paid from the UK because this exemption does not require that the payer is a "European Company".

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