Dividends taxation: source state may tax with limited withholding; residence may claim tax credit or refund. Payments characterised as dividends may be taxed in the recipient's residence state, while the source state may also tax them subject to a cap when the recipient is the beneficial owner. Eligible residents may claim from the French Treasury an amount equivalent to the French tax credit (avoir fiscal), subject to deduction of the applicable withholding tax; this entitlement is limited to specified classes of residents and excludes dividends effectively connected with a permanent establishment or fixed base.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividends taxation: source state may tax with limited withholding; residence may claim tax credit or refund.
Payments characterised as dividends may be taxed in the recipient's residence state, while the source state may also tax them subject to a cap when the recipient is the beneficial owner. Eligible residents may claim from the French Treasury an amount equivalent to the French tax credit (avoir fiscal), subject to deduction of the applicable withholding tax; this entitlement is limited to specified classes of residents and excludes dividends effectively connected with a permanent establishment or fixed base.
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