European Commission Calls on France to Remove Restriction in Breach of Parent-Subsidiary Directive

As noted in its March 2026 infringements package, the European Commission has sent a letter of formal notice calling on France to remove a restriction in breach of the Parent-Subsidiary Directive. The issue is that France applies its own criteria in determining whether a parent company qualifies for the withholding tax exemption on distributions by a subsidiary, requiring that the parent compa…