On 5 June 2020, the French Supreme Administrative Court (Conseil d'Etat) issued its decisions in four cases regarding eligibility for the dividend withholding tax exemption under the Parent-Subsidiary Directive (PSD). The PSD provides, inter alia, for a withholding tax exemption for profit distributions made by qualifying EU subsidiaries to their qualifying EU parents.
The directive specifies that it does not preclude the application of domestic or agreement-based provisions required for th…