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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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Article 117 bis of the French General Tax Code

Remuneration allocated to members of the board of directors or supervisory board of public limited companies, in any capacity whatsoever, excluding salaries and industrial property royalties, give rise to the withholding tax referred to in article 119 bis. However, emoluments allocated to directors or members of the supervisory board in salaried employment as remuneration for that employment remain subject to the payroll tax regime.

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Article 117 quater of the French General Tax Code

I.-1. Individuals domiciled in France for tax purposes within the meaning of article 4 B who benefit from distributed income mentioned in articles 108 to 117 bis and 120 to 123 bis are subject to a levy at the rate of 12.8% . For the calculation of this levy, the income mentioned in the first paragraph of this 1 is retained for its gross amount. However, natural persons belonging to…

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Article 118 of the French General Tax Code

For the purposes of the present provisions, the following shall be deemed to be income: 1° Interest, arrears and any other proceeds from bonds, participating securities, public bills and any other negotiable debt securities issued by the French State, departments, communes and public establishments, associations of any kind and any French financial, industrial, commercial or civil companies, corporations and enterprises; 2° Redemption lots and premiums paid to holders of the…

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Article 119 of the French General Tax Code

Income is determined: 1° For bonds, participating securities, public bills and loans, by the interest or income distributed during the year; 2° For lots, by the amount of the lot itself; 3° For redemption premiums, by the difference between the sum redeemed and the issue rate of the loans. A decree (1) shall determine the issue rate to be used to calculate the tax on these premiums. (1) Annex III,…

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Article 119 bis of the French General Tax Code

1. Income from transferable capital falling within the provisions of articles 118,119,238 septies B and 1678 bis give rise to the application of a withholding tax, the rate of which is set by 1 of Article 187, when they benefit persons who have their registered office in France or abroad or who do not have their tax domicile in France. However, income from debt securities mentioned in the first paragraph…

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Article 119 bis A of the French General Tax Code

1. Is deemed to constitute distributed income subject to the withholding tax provided for in Article 2 of 119 bis any payment, up to the amount corresponding to the distribution of proceeds from units or shares referred to in b, made, in any form and by any means whatsoever, by a person who is established or has his tax domicile in France to the benefit, directly or indirectly, of a…

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