Tue, Dec 1, 2015
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

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. David Einhorn's hedge fund plunged 5.2% in November, set for 2015 loss[more]

    From Bloomberg.com: David Einhorn’s main hedge fund at Greenlight Capital fell 5.2 percent in November and is poised for only its second losing year in almost two decades. The losses bring the fund’s yearly drop to almost 21 percent, according to an e-mail sent to clients that was obtained by Bloomb

  2. People - Solus Alternative Asset Management adds chief strategist from BTIG[more]

    From PIonline.com: Daniel Greenhaus joined hedge fund manager Solus Alternative Asset Management as managing director and chief strategist. He will work closely with Chris Bondy, Solus’ chief economist, managing director and executive vice president, said Chris Pucillo, CEO and chief investmen

  3. Commodities - Stung by oil, distressed-debt traders see worst losses since '08[more]

    From Bloomberg.com: It’s mid-November, but for investors who trade in the debt of distressed companies, the year’s already done -- and they lost. Hedge funds that specialize in the debt are grappling with their worst declines in seven years. Funds managed by Knighthead Capital Management, Candlewood

  4. Regulatory - Major changes in partnership audit procedures contained in 2015 Budget Act[more]

    Contained in the Bipartisan Budget Act of 2015, signed by President Obama on November 2, is a rather complex provision that materially changes how partnerships are audited. Generally effective for tax years beginning after December 31, 2017, the so-called “TEFRA” and “Electing Large Partnership” rul

  5. Following review Yuan included in reserve currency basket[more]

    Bailey McCann, Opalesque New York: The International Monetary Fund has confirmed the inclusion of the Chinese Yuan in the reserve currency basket. This means that loans will be available in Yuan alongside other major currencies including the US Dollar and the Euro. The basket of reserve curr