French Supreme Administrative Court

decides on concept of beneficial owner under France-UK tax treaty

On 29 December 2006, the French Supreme Administrative Court overturned an earlier decision from the Court of Appeals of Paris dealing with the concept of beneficial ownership under the France-UK tax treaty. The Supreme Administrative Court concluded that a Scottish bank, which had acquired dividend coupons under a usufruct agreement with a US company, was not the beneficial owner of the dividends d…