Article 115 ter of the French General Tax Code
Where a company having its registered office in France and liable to the tax provided for in Chapter II of this Title carries on business in Saint-Pierre-et-Miquelon, Mayotte, New Caledonia, French Polynesia, the Wallis and Futuna Islands and the French Southern and Antarctic Territories where taxation is applied to distributions of profits, the double taxation to which distributions of profits made by this company may be subject as a result…