The French Constitutional Court (Conseil Constitutionnel) recently issued a decision on whether the previously allowed deduction (neutralization) of the taxable 5% proportion (add-back) for costs and expenses under the French participation exemption regime for qualifying dividends was in line with the constitutional principle of equality. The neutralization of the 5% add-back was abolished from 2016 after it was found by the Court of Justice of the European Union to be incompatible with the …