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France had the lender been a French tax resident) This Participation exemption on dividends amendments to participation exemption regime on dividends



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French tax (and foreign-source losses may not be deducted) Taxable income A participation exemption on dividends applies where the recipient owns at 



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France provides for a participation exemption for dividends and capital gains There are transfer pricing, controlled foreign company and thin capitalization regimes 



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or enterprises the taxation of which is attributed to France under a tax treaty participation shares, i e shares qualifying for the participation exemption, shares



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Participation exemption Gains from the alienation of qualifying participations are exempt from corporate income tax, subject to the add-back of 12 of the gross



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gains realised (90 per cent exempt) upon a substantial (i e , at least 5 per cent) participation in French and foreign companies or partnerships (unless 



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at the French tax actually due on the net income The portion of the credit exceeding the cap is forfeited Participation exemption – A participation 



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