France: Originals of tax certification required – reminder
Clearstream Banking1 reminds customers of the obligation to provide the originals of the certification to be eligible to obtain relief at source or standard refund on French-sourced equities. The French Tax Authorities (FTA) confirmed that the exceptional measures granted due to COVID-19 were temporary and that Clearstream Banking must receive all originals by the end of 2020.
Background
To allow beneficial owners to obtain relief at source through the simplified procedure, in the context of a lockdown in many countries, the FTA allowed withholding agents to apply the reduced rates or exemptions based on the form 5000s provided in 2019. The extension of the validity was first granted until 30 April 2020 and thereafter extended until 15 July 2020. For details, please refer to C20008 and C20029.
The FTA also accepted that the form 5000s did not require to be certified in Box IV by the beneficial owner’s tax authorities but could rather be certified with a separate certificate of residence (COR) for both relief at source and standard refund. This temporary measure is applicable until the end of 2020. For details, please refer to C20008 and C20038.
Copies of the certification (form 5000s, RPPM) were also accepted on the condition thatthe executed originals would be provided at the date the customer would return to the usual operational working conditions.
Clearstream Banking trusts that most of customers have had the opportunity during the past months to come back to working conditions allowing them to provide the originals as expected.
Impact on customers
Customers who provided copies of certification for the simplified procedure or standard refund or who could not yet renew their form 5000s for 2020, must ensure that they provide Clearstream Banking with their originals at the latest by 15 December 2020.
Failing to provide the originals of the certification or to renew the form 5000s for 2020 will result in the application of the full 28% withholding tax rate to all dividends received since 1 January 2020 that were not duly certified with an original.
Further information
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.