Beneficial ownership from a French perspective

26 July 2023 Publications

Written by Pierre-Henri Durand and Victor Camatta

Published on European Tax Blog

Increasingly, the French tax authorities are making use of the beneficial ownership concept to deny withholding tax exemptions (or the application of a reduced rate of withholding tax) for dividends and royalties, either pursuant to domestic law or a double tax treaty. The position in respect of interest is slightly different due to a broad domestic exemption. Read more