France: Finance Bill for 2020 approved by the French National Assembly


The Finance Bill for 2020 has been submitted by the French Government to the National Assembly.

Several proposed measures impacting the taxation of non-resident investors were adopted by the National Assembly: 

  • The progressive decrease in the rate of withholding tax on income from French equities to 28% as of 1 January 2020, 27.5% as of 1 January 2021 and 25% as of 1 January 2022. This measure, already part of the 2018 Finance Bill announced in A17190 and D17084, was revised and included in this new finance law (Article 11 of the Bill). 
  • The temporary tax refund and tax deferral for non-resident companies in loss making situation. This measure results from the decision of the European Court of Justice dated 22 November 2018 (case C-575/17 Sofina SA, Rebelco SA and Sidro SA) (article 12 of the Bill).
  • The exemption from withholding tax of companies in compulsory liquidation, applicable to dividend distributions is extended to all other types of income and profits subject to tax.(article 12 of the Bill).

If approved by the French Senate these measures will be effective as of 1 January 2020. 

We will inform customers as soon as official confirmation becomes available.

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