Article 143 quater of the French General Tax Code
Distributions of profits made by companies that have entered into an agreement with the Minister of the Economy and Finance in accordance with the provisions of l’ordonnance n° 59-248 du 4 février 1959, are exempt from the withholding tax provided for in 2 of Article 119 bis insofar as the profits distributed come from the activities of the company referred to in the agreement and do not exceed 5% of…