The Tax Administration of France published on 11 May 2016 guidelines on the taxation of dividends distributed within tax-consolidated groups following changes brought by the Amending Finance Law 2015.
For financial years commencing on or after 1 January 2016, dividends qualified for the participation exemption and received by a member company of a tax-consolidated group like from a (French) subsidiary belonging to the same tax-consolidated group will no longer be fully exempt, but will give rise to a 1% add-back or from an EU or EEA subsidiary that would meet the conditions required for belonging to the tax-consolidated group if it were French will give rise to a similar 1% (previously 5%) add-back.
