The French Administrative Supreme Court requested in a decision on 17 January 2007 a preliminary ruling from the European Court of Justice (ECJ) on specific aspects of the French participation exemption set in Art. 216 of the French tax Code (Code Général des Impôts (CGI)). Details of the decision are summarized below.
Background
Under Art. 4 of the Parent-Subsidiary Directive he exemption method may provide that "any charges relating to the holding and…