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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…

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Article 115 quinquies of the French General Tax Code

1. Profits made in France by foreign companies shall be deemed to be distributed, in respect of each financial year, to shareholders who do not have their tax domicile or registered office in France. The profits referred to in the first paragraph shall mean the total amount of profits, whether taxable or exempt, after deduction of corporation tax. 1. bis (Provisions not applicable). 2. However, the company may request that…

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Article 116 of the French General Tax Code

For each tax period, the mass of distributed income determined in accordance with the provisions of articles 109 to 115 ter is considered to be allocated between the beneficiaries, for the assessment of the income of each of them, up to the figures indicated in the declarations provided by the legal entity under the conditions provided for in 2° of 2 of article 223.

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Article 117 of the French General Tax Code

In the event that the total amount of distributed income exceeds the total amount of distributions as it results from the declarations of the legal entity referred to in Article 116, the latter is asked to provide the administration, within thirty days, with any additional information on the beneficiaries of the excess distribution. In the event of refusal or failure to reply within this period, the corresponding sums shall give…

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