French Tax Update - Recently Published Noteworthy Publications

The present French Tax Update will focus on an overview of several significant publications, including: (i) noteworthy French court decisions issued in the last months (regarding inter alia the tax treatment of a waiver of debt and of a share buyback performed at a discounted price, the comparability of foreign pension funds to French nonprofit organizations for French withholding tax purposes, and the VAT recovery rights of mixed holding companies); (ii) a new request on the issue of constitutionality in respect of the exclusion from the participation-exemption regime for dividends of non-voting shares; (iii) the request by the European Commission to France to end the discriminatory treatment of dividends from nonresident subsidiaries (in respect of the longstanding précompte mobilier cases); and (iv) an update on the Anti-Tax Avoidance Directive.

Please contact Siamak Mostafavi if you are interested in this issue.

Jones Day publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information purposes only and may not be quoted or referred to in any other publication or proceeding without the prior written consent of the Firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our "Contact Us" form, which can be found on our website at The mailing of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship. The views set forth herein are the personal views of the authors and do not necessarily reflect those of the Firm.