The French tax authority recently published two rulings regarding the application of dividend withholding tax on payments made by banks to non-residents in respect of financial transactions considered dividend equivalents.
The first ruling is in response to a question on whether a bank is obligated to deduct withholding tax under Article 119 bis of the General Tax Code (CGI) on "dividend equivalent" payments to non-residents. The ruling confirms that the withholding tax under Article 119 bi…