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Article 119 ter of the French General Tax Code

1. The withholding tax provided for in 2 of article 119 bis is not applicable to dividends distributed to a legal entity that meets the conditions listed in 2 of this article by a company or organisation subject to corporation tax at the standard rate. 2. In order to benefit from the exemption provided for in 1, the legal entity must prove to the debtor or the person who ensures…

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Article 119 quater of the French General Tax Code

1. The withholding tax provided for in 1 of article 119 bis as well as the levy provided for in III of Article 125 A is not applicable to interest understood, for the application of this article, as income from debts of any kind, excluding penalties for late payment, paid by a société anonyme, a société par actions simplifiée, a société en commandite par actions, a société à responsabilité limitée,…

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Article 119 quinquies of the French General Tax Code

The withholding taxes or levies provided for in articles 119 bis, 182 A bis, 182 B, 244 bis, 244 bis A and 244 bis B are not applicable to income and profits received or realised by a legal entity which provides evidence to the debtor or the person who ensures the payment of this income that it fulfils, in respect of the financial year during which it receives or realises…

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Article 120 of the French General Tax Code

Sont considérés comme revenus au sens du présent article : 1° Dividends, interest, arrears and all other income from shares of any kind and founders’ shares in financial, industrial, commercial, civil and generally any other companies, corporations or enterprises whose registered office is situated abroad regardless of when they were created; 2° Interest, income and profits from interest shares and limited partnerships in companies, corporations and enterprises whose registered office…

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Article 121 of the French General Tax Code

1. For the application of Article 120, the incorporation of reserves by a foreign company into its share capital does not constitute a chargeable event for income tax. The provisions set out in 1 of Article 115 are applicable in the event of a merger or demerger involving companies at least one of which is foreign. The provisions set out in 2 of article 115 are applicable in the event…

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Article 122 of the French General Tax Code

1. Subject to 2, the income is determined by the gross value in euros of the products collected according to the exchange rate on the day of the payments, without any deduction other than that of the taxes established in the country of origin and the payment of which is the responsibility of the beneficiary. The amount of the lots is fixed by the actual amount of the lot in…

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Article 123 of the French General Tax Code

With regard to funding securities issued by foreign States, the taxable event is deferred to the time of the first negotiation of these securities. In this case, the taxable income is determined by the negotiation price.

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Article 123 bis of the French General Tax Code

1. When an individual domiciled in France holds directly or indirectly at least 10% of the shares, units, financial rights or voting rights in a legal entity-a legal person, body, trust or comparable institution-established or incorporated outside France and subject to a privileged tax regime, the profits or positive income of this legal entity are deemed to constitute income from movable capital of this individual in the proportion of the…

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Article 124 of the French General Tax Code

Sont considérés comme revenus au sens du présent article, lorsqu’ils ne figurent pas dans les recettes provenant de l’exercice d’une profession industrielle, commerciale, artisanale ou agricole, ou d’une exploitation minière, les intérêts, arrérages, primes de remboursement et tous autres produits : 1° Des créances hypothécaires, privilégiées et chirographaires, à l’exclusion de celles représentées par des obligations, effets publics et autres titres d’emprunts négociables entrant dans les prévisions des articles 118…

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