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French Administrative Court Holds Dividends May Qualify for Group Participation Exemption Under Tax Treaty with Chile

|Treaty Development|France-Chile
France-Chile

The French Administrative Court of Montreuil recently issued a decision regarding whether dividend paid by subsidiaries in Chile to a parent company in France may qualify for the 99% (100% prior to 2016) participation exemption for group dividends (95% or greater holding). In the case concerned, the French tax authority determined that the dividends only qualified for the 95% participation exem…

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