French Tax Authorities release new guidelines on dividend withholding tax exemption for foreign collective investment vehicles

The French Tax Authorities have amended their guidelines related to the withholding tax exemption set forth by Article 119 bis 2 of the French tax code (FTC) on French dividends paid to certain nonresident regulated collective investment vehicles (CIVs). As background, this exemption (Article 119 bis 2 of the FTC) was implemented on 17 August 2012. It was enacted following the European Court of Justice (ECJ) Santander decision that considered the previous French withhold…