A recent decision of the Administrative Court of Appeal of Paris has been published concerning the substantiation of claims for a tax credit in relation to dividends received under the 95% participation exemption in cases where the actual costs are less than the taxable 5% add-back that represents non-deductible costs related to a participation. As previously reported, the French Supreme Court (Conseil d'Etat) issued a decision on 5 July 2022 finding that the required add-back results in an …