On 6 October 2017, the French Constitutional Court (Conseil Constitutionnel) issued its decision that the 3% surtax on profit (dividend) distributions is unconstitutional. The decision follows a decision of the Court of Justice of the European Union (CJEU) that dividends distributed by a French company that represent a redistribution of dividends received from its EU subsidiaries cannot be subject to the 3% surtax on profit distributions, as this would be a form of a double taxation in viola…