On 18 November 2016, the French Government submitted the draft Amending Finance Bill for 2016 to the National Assembly. Two of the main amendments in the bill are in relation to the exemption from the tax on profit distributions for French tax-consolidated groups and the 5% voting rights requirement for the dividends participation exemption — both of which have been ruled unconstitutional.
Profit Distribution Tax Exemption Amendments
Under current rules, French tax-consolidated groups are …