Investment Incomes

Shares stripping

Granting conditions of the tax credit

Article 158 ter 1, 3rd paragraph of the French General Tax Code resulting from article 45 of the law no 93-1353 dated December 30, 1993 provides that in case of stripping of the shares ownership between legal persons, the right to tax credit of the beneficiary of the dividends may be suppressed when the owner of the rights, other than dividends rights, is a non-resident. A directive dated March 1st, 1996, 4J-2-96, gives comments and examples on this provision.

- Article 158 ter of the French General Tax Code provides that the tax credit ("avoir fiscal") exclusively applies to incomes of stocks, partner's shares or founder's shares, the distribution of which results from a regular decision of the company. The "avoir fiscal" is attributed to persons having their actual domicile or registered office in France.