Sun, Aug 31, 2014
A A A
Welcome Guest
Free Trial RSS
Get FREE trial access to our award winning publications
Alternative Market Briefing

EU UCITS and alternative investment funds can benefit from withholding tax exemption in France

Tuesday, September 10, 2013

amb
Markus Hammer
Benedicte Gravrand, Opalesque Geneva:

The French tax authorities recently rethought their withholding tax process.

A withholding tax is a tax levied on income (interest and dividends) from securities owned by a non-resident.

Normally, dividends paid by a French corporation to a non-resident shareholder are subject to a 30% withholding tax calculated on the gross dividends, although interest paid by a French company to a non-resident is not usually subject to tax.

According to a Tax Newsflash issued by PWC (PricewaterhouseCoopers) last week, France, after the ECJ Santander case in May 2012, removed the discrimination between resident and non-resident funds. French source dividends paid to non-French funds should no longer suffer French WHT, provided the fund resides in the EU, raises capital among several investors to invest in their interest, and operates "under conditions similar to those applicable under French law."

Further to that, the French tax authorities published new guidelines in August 2013, stating that there should be a general distinction between EU funds and non EU-funds, i.e.:

• Investment funds located in an EU Member State or EEA (European Economic Area) would obtain the withholding tax exemption subject to certain conditions / filing process. • Investment funds located outside the EU would remain su......................

To view our full article Click here

Today's Exclusives Today's Other Voices More Exclusives
Previous Opalesque Exclusives                                  
More Other Voices
Previous Other Voices                                               
Access Alternative Market Briefing
  • Top Forwarded
  • Top Tracked
  • Top Searched
  1. Study shows what resonates with investors: 'Unwavering', 'passionate' beats 'committed', 'dedicated' and more surprises[more]

    Komfie Manalo, Opalesque Asia: A new study by Pershing Square, a unit of BNY Mellon company, showed that an effective value proposition strengthens audience connections and fosters growth, yet many advisors have had little objective guidance in formulating such statements until now. In the

  2. Comment – Why you should avoid the hottest hedge fund hands, Swedroe attacks Hussman over risk management, relative value strategy[more]

    Why you should avoid the hottest hedge fund hands FromCNBC/Yahoo.com: Investors who don't have money with Pershing Square Capital Management are likely salivating at the hedge fund's industry-leading 26 percent return from January through July. But investing with Bill Ackman and other to

  3. AIMA makes 'the case for hedge funds'[more]

    Bailey McCann, Opalesque New York: The Alternative Investment Management Association (AIMA), the global hedge fund industry body,

  4. Managed futures' global diversification is important in next phase of economic recovery[more]

    Komfie Manalo, Opalesque Asia: The global diversification provided by managed futures may prove to be extremely valuable as the markets enter the next phase of the economic recovery, said Campbell & Company, a pioneer in absolute return invest

  5. Ex-UBS prop trader's hedge fund Manikay Partners eyes UK launch[more]

    From eFinancialnews.com: Manikay Partners, a $1.7 billion US multi-strategy hedge fund set up in 2008 by a proprietary trader from UBS with backing from Goldman Sachs, is planning to open in the UK. New York-based Manikay's move into Europe comes after Financial News revealed on Monday that Aurelius