The French Supreme Court (Conseil d'Etat) issued a decision on 5 July 2022 in a case concerning the 95% participation exemption for dividends received, which is increased to 99% if certain conditions are met. Under the participation exemption regime, the taxable 5% (1%) proportion (add-back) represents non-deductible costs related to the participation. As per guidance issued in March 2021 (BOI-IS-BASE-10-10-20), the tax authority stated that this add-back cannot be considered as leading to t…