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 company's place of effective management is located in a Member State. This is not in line with the Direct…