A recent decision of the Administrative Court of Appeal of Paris has been published on whether dividends received in 2015 by a French company from a wholly-owned subsidiary in Chile qualify for the neutralization of the taxable 5% add-back that represents non-deductible costs related to a participation when receiving dividends under the French parent-subsidiary regime. While it has been settled that the neutralization should be allowed with respect to dividends received from companies in oth…