France: Foreign UCITSs not liable to pay French dividend withholding tax
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The European Court of Justice has ruled that the application of French withholding tax on dividends paid to foreign UCITSs is considered as discriminatory, as French domiciled UCITSs are considered as exempt from withholding tax in France.
The discrimination must be compared at the UCITS level only and not at the level of the underlying shareholders.
Not all information is currently available and the French government and French Tax Authorities are yet to provide clear guidelines. We will advise in due course of any relief and/or reclaim procedures that become available for customers with regard to these UCITSs.