France: Extension of validity of certificates of residence submitted by U.S. residents in 2018
Clearstream Banking1 informs customers that due to the U.S. government shutdown the French Tax Authorities decided to extend the period of validity of the certificates of residence (CORs) if submitted by U.S. tax residents for the application of the relief at source procedure on French-sourced income.
CORs provided by U.S. tax residents in 2018 remain valid until 30 April 2019.
Customers that use the simplified procedure to claim relief at source from tax withheld on dividends must renew their CORs (Form 5000 and Form 6166) for 2019 as soon as possible and at the latest 10 business days before the first dividend payment date to which it applies.
However, for beneficial owners for whom a COR for 2018 has been submitted, its validity is generally extended until 31 March 2019 on condition that a new COR is submitted by the end of March 2019.
Please refer to the procedure of renewal of CORs described in L18034.
Following the decision of the FTA to extend the validity of the CORs for U.S. residents, the above deadline of 31 March 2019 does not apply to these specific entities.
Impact on customers
CORs provided in 2018 by eligible U.S. residents in order to benefit from the application at source of tax treaty rates on their French-sourced dividends remain valid until 30 April 2019 instead of 31 March 2019, on condition that new CORs are submitted by the end of April 2019.
If no new COR is submitted by the end of April 2019, reversals will be required for this payment period and the 30% domestic withholding tax rate will be applied retroactively.
For further information about the withholding tax procedures for French equities, please refer to the Clearstream Banking Market Taxation Guide - France.
For further information, please contact the Clearstream Banking Tax Help Desk or Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.