France: Information on relief at source certification to provide to BNP and/or CBF as withholding agent
Clearstream Banking1 would like to inform customers that through several publications since 2017 related to the T2S migration, and in Announcements A17174, A17186 and A19014, customers were informed of the necessity to provide French tax certifications in duplicate when holding the securities through both Clearstream Banking S.A. (CBL) and Clearstream Banking AG (CBF), to cover the withholding agent’s activities for both CBF and BNP Paribas Securities Services (BNP). Customers holding securities with only one of the above (either CBL or CBF) only need to provide one set of certificates to the related withholding agent.
Background
Following the different phases of migration of French securities to the T2S platform, most securities are now held through CBF as withholding agent and only very few securities may remain deposited with BNP as withholding agent. A list of non-migrated securities is attached below.
Depending on their holdings, customers should clarify whether they still hold securities that have not migrated to CBF and if it is still relevant to provide two originals of tax forms 5000, RPPM or a certificate of residence for the purpose of relief at source of French dividend tax.
Impact on customers
When renewing the tax certification for relief at source of French dividend tax (forms 5000, RPPM or certificates of residence), customers are required to verify if the securities held in their portfolio are T2S securities deposited with CBF or non-T2S securities deposited with BNP.
Customers holding exclusively T2S or non-T2S securities must provide only one original of the tax documentation. If the certification is provided to cover non-T2S securities, it must be specified on the cover letter that the forms are for the attention of BNP as withholding agent.
Customers holding both T2S and non-T2S securities must continue to provide two originals (for example, one for each withholding agent).
Continuing to provide two originals when not needed will create an unnecessary workload at the level of all intermediaries and final investors and may result in a longer treatment of the certification received.
Further information
Please refer to Market Taxation Guide – France for further details on the relief at source process and deadlines.
For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
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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.