As parliamentary discussions continue for France's Amended Finance Bill for 2014, provisions have been added to counter hybrid-mismatch arrangements resulting in double non-taxation. The provisions are in line with the amendment to the EU Parent-Subsidiary Directive adopted by the EU Council.
Under the provisions, the participation exemption for income from shares would be denied if:
- The income is paid out of profits not subject to corporate income tax or similar tax, or
- The income is tax d…