Removal of withholding tax on dividends paid to foreign investment funds
Article 6 of the second amending finance act for 2012 removes withholding tax on French-source dividends paid to foreign collective investment undertakings established in the European Union or in a State that has an administrative assistance agreement with France, where they have features similar to French funds. Withholding tax remains due on income paid in a non-cooperative State or territory. The measure applies to distributions paid from 17 August 2012 and follows a ruling of the Court of Justice of the European Union finding the difference in treatment contrary to EU law.
Measure originators
European origin
EUA positive amount is revenue or savings for public finances; a negative amount is a cost or lost revenue.
Measure impact
Foreign funds invested in French shares receive their dividends without withholding tax, like French funds. According to the Senate finance committee report, exempting foreign undertakings results in a revenue loss of about €800 million a year.
Official references
Sources
Procedure timeline
Follow the progress of this fiscal measure through the different stages of the parliamentary procedure.
Administrative implementation
Entrée en vigueur de la mesure et mise en œuvre par l'administration
President of the Republic signature
Publication au Journal officiel
Possible referral to Constitutional Council
Décision de conformité / censure partielle
Joint committee
Désaccord éventuel
Debate and vote
Debate and vote
Débat et vote en séance publique à l'Assemblée nationale, ou engagement de la responsabilité du Gouvernement (article 49.3)
Council of Ministers
Validation interne