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Clifford Chance

Clifford Chance

Briefings

French tax authorities opine on withholding tax treatment of manufactured dividends

21 February 2023

On 15 February 2023, the French tax authorities issued two public rulings relating to the withholding tax treatment of manufactured dividends paid by French banks to non-residents. The interpretation retained by the French tax authorities in these tax rulings considerably extends the scope of French dividend withholding tax rules to encompass manufactured dividend payments made notably under temporary acquisitions of French equities and derivatives transactions with an underlying in French equities.

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