Dividend taxation: withholding limited where recipient is beneficial owner; French tax credit payment available to eligible Indian recipients. Taxation of dividends allocates primary taxing rights to the recipient's State but permits the payer's State to tax dividends paid to beneficiaries, subject to a withholding limit when the recipient is the beneficial owner. Certain Indian residents (individuals and companies holding less than ten percent) may claim a French Treasury payment equivalent to the French tax credit, subject to withholding and Indian taxability. Prepayments (precomptes) may be refunded with deduction of withholding where the French Treasury payment is not available. An exception applies where dividends are 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.
Dividend taxation: withholding limited where recipient is beneficial owner; French tax credit payment available to eligible Indian recipients.
Taxation of dividends allocates primary taxing rights to the recipient's State but permits the payer's State to tax dividends paid to beneficiaries, subject to a withholding limit when the recipient is the beneficial owner. Certain Indian residents (individuals and companies holding less than ten percent) may claim a French Treasury payment equivalent to the French tax credit, subject to withholding and Indian taxability. Prepayments (precomptes) may be refunded with deduction of withholding where the French Treasury payment is not available. An exception applies where dividends are effectively connected with a permanent establishment or fixed base.
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