The French tax authority has issued a Ruling dated 18 December 2024 on the availability of a foreign tax credit (FTC) in France in cases where foreign withholding tax is deemed to be contrary to the provisions of a relevant tax treaty. French law stipulates that FTCs are available only with respect to foreign taxes that are levied in a manner compatible with the provisions of the relevant tax treaty. This was long largely interpreted to mean that in situations where a foreign tax is deemed t…