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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......................

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