French Parliamentary response on non-eligibility of Luxembourg SICARs to France-Luxembourg tax treaty and EC Parent Subsidiary Directive

In a Parliamentary Response of 4 July 2006, the French Ministry of Finance stated that a Luxembourg sociétés d'investissement en capital à risque (SICARs) could not benefit from the reduced withholding tax rate under the France-Luxembourg tax treaty and from the exemption from dividend withholding tax under the EC Parent-Subsidiary Directive ((90/435/EEC).

According to the Ministry, SICARs would only be eligible to the application of the reduced rates set out i…