France’s regulations on withholding tax are in breach of EU treaties and have now had to quickly implement some precedent into national law. As per the C-575/17, Sophina SA, Rebellco SA and Sydro SA case; going forward any dividends paid by a loss-making parent require the immediate taxation charged to non-resident companies.

The European Court of Justice has ruled that Companies resident in other EU Member States that were found to be in a deficit for some financial years can now try to recover withholding tax paid on French-sourced stocks and shares.