The French Supreme Court in a decision of 25 July 2025 ruled on the correlation between the French participation exemption regime and foreign exchange gains and losses.
The participation exemption regime permits the exemption of dividends from qualifying holdings. Under the standard rules, 95% of the amount of dividends received are exempt from corporate tax, while the remaining 5% are deemed to correspond to the expenses borne with respect to the holding and are assessed to corporate tax.
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