On 11 March 2021, the French tax authority published a guidance document (BOI-INT-DG-15-20) regarding the withdrawal of the UK from the EU, including guidance in relation to transition provisions for the tax treatment of dividend distributions, tax groups, and other matters. The transitional provisions are summarized as follows:
Dividend distributions from the UK
Transitional provision - For dividend distributions made to a French group company by a UK company with a fiscal year ongoing a…