Wednesday 2 September 2015

Europe: freedom of establishment and the tax treatment of dividends

The opinion of the Court of Justice in Groupe Steria SCA v Ministère des Finances et des Comptes publics (Case C-386/14) was delivered today. The court held that a particular rule of French tax law - the effect of which was, in certain circumstances, to treat dividends received by a parent company differently depending on whether the subsidiary was resident in France or another Member State - was not compatible with Article 49 ("Right of establishment") of the Treaty on the Functioning of the European Union. A summary of the opinion is available here (pdf).

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