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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>France Convention Article 8: Dividend Tax Exemptions Require 365-Day Ownership for Double Tax Avoidance, Prevents Treaty Abuse.</h1> Article 8 of the France Convention addresses Dividend Transfer Transactions under Double Tax Avoidance Agreements (DTAA) to prevent treaty abuse. It specifies that tax exemptions or rate limitations on dividends apply only if ownership conditions are met for a continuous 365-day period, excluding changes due to corporate reorganizations. This minimum holding period replaces or supplements existing provisions in tax agreements. Parties can reserve the right to exclude this article from their agreements, especially if existing provisions already include a holding period. Notifications are required from parties not reserving rights, ensuring mutual agreement on the application of these provisions.
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