The imposition of branch remittance tax on income earned in France by a Hong Kong resident company was clarified by the Inland Revenue Department on 27 December 2012.
Income earned in France by a foreign company is deemed to be distributed to a foreign resident under the French Tax Code and, in the absence of the treaty, a 25% withholding tax (branch remittance tax) is levied on that after-tax income as if it were dividends, unless the enterprise proves that the income taxed exceeds the …