The French Administrative Court of Montreuil recently issued a decision regarding whether dividend paid by subsidiaries in Chile to a parent company in France may qualify for the 99% (100% prior to 2016) participation exemption for group dividends (95% or greater holding). In the case concerned, the French tax authority determined that the dividends only qualified for the 95% participation exemption, which is available for 5% or greater holding. The French company argued, however, that it sho…