The French Supreme Administrative Court (Conseil d'Etat) recently issued its decision concerning the correct withholding tax treatment for dividends paid by a French company to the Korean National Pension Service (NPS), which is the pension fund in charge of the general Korean old-age insurance scheme. In the tax year 2013, dividends paid to the NPS were initially subject to withholding tax at a rate of 30% (domestic rate at the time), although after a complaint was submitted, the rate was re…