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

|Approved Changes|France-United Kingdom
France-United Kingdom

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 group…

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