On 2 September 2015, the Court of Justice of the European Union (CJEU) ruled on an issue referred to the Court by the Versailles Administrative Court of Appeal concerning a French company seeking to deduct the 5% proportion for costs and expenses related to dividends received from subsidiaries established in other EU Member States. This would be allowed for dividends received from a French subsidiary under the French tax integration regime, but not for dividends received from a non-resident s…