SALE OF A FRENCH SHAREHOLDING BY A FOREIGN COMPANY: NEW OPPORTUNITIES FOR CAPITAL GAINS TAX REFUNDS!
by Hélène Relange, Pierre-Antoine Farhat and Alexandra Delbarre, Lamy Lexel, France Under the terms of Article 244 bis B of the French Tax Code (“Code général des impôt”), foreign companies holding more than 25% of a French company’s share capital must pay a 25% tax (French corporate tax rate) on the capital gain realized on