Thu, Sep 29, 2016
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. Nobel Sustainability Trust, Prince Albert II of Monaco help launch major new initiative to drive sustainable technologies[more]

    Matthias Knab, Opalesque: The Nobel Sustainability® Trust ("NST") is leading a major new initiative to finance, incubate and accelerate the development of clean technologies. The initiative will start with the formation of the Nobel Sustainability Fund® ("NSF"). NSF will drive faster access t

  2. Studies - Hedge funds’ study reveals vast disparity in types of investors securing side letter arrangements, Cambridge: Look to private investments for best access to LatAm growth[more]

    Hedge funds’ study reveals vast disparity in types of investors securing side letter arrangements A new study of the hedge fund space by industry law firm Seward & Kissel LLP reveals a wealth of information regarding established hedge fund managers’ use of side letters—special agreements

  3. Activist News - Caesars 'optimistic' on deal with hedge fund creditors[more]

    From Reuters.com: Caesars Entertainment Corp said on Monday it remains "optimistic" of reaching a $5 billion deal with the bulk of its creditors to push its main operating unit out of bankruptcy, but one hedge fund bondholder said it will pursue litigation. Caesars offered a sweetened $5 billion set

  4. Hedge funds recover from losses as central banks give markets a respite[more]

    Komfie Manalo, Opalesque Asia: The Lyxor Hedge Fund index was up 0.4% from the week ending September 20 (-2.4% YTD), supported by the willingness of central banks to remain accommodative, Lyxor Asset Management said in its weekly briefing. It ad

  5. Perry Capital closing flagship fund after almost three decades[more]

    From Blooomberg.com: Richard Perry, one of the biggest names in hedge funds, is calling it quits after 28 years. Perry, 61, is winding down his New York-based flagship fund as the industry confronts one of the most tumultuous periods in its history. In a letter to investors Monday, he said his style