Article 115 quinquies of the French General Tax Code
November 8, 2023
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…
