On 30 September 2016, the French Constitutional Court (Conseil Constitutionnel) issued its decision that the exemption from the 3% tax on profit (dividend) distributions only available for French tax-consolidated groups is unconstitutional ({News-2016-07-05/P/2- previous coverage}). The relevant provisions for the exemption will be repealed effective 1 January 2017, which gives the French government time to address the differing treatment of distributions. This may include expanding the scope…