04 October 2016 France's 3% distribution tax exemption applicable within tax consolidated groups violates French Constitution The French Constitutional Court (FCC) ruled on September 30, that the currently applicable legal provisions providing a 3% dividend tax exemption for distributions made within a French tax consolidation violates the French Constitution. However, this decision will only take effect as of January 1, 2017. Therefore, distributions made within a French tax consolidation until December 31, 2016 would still be exempt from the 3% distribution tax. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1688 |
