S&C Lawyers Publish Article in French Tax Law Journal Bulletin Fiscal

April 2011

In the April 2011 issue of the French tax law journal Bulletin Fiscal, Mr. de Boynes, Mr. Bachellerie and former associate Mr. Message published an article titled, “French Withholding Taxes and Non-Discrimination Clauses.” The article discusses French case law on non-discrimination clauses included in tax treaties. According to recent court decisions, non-discrimination clauses may forbid withholding tax on dividends paid by French companies to non-French entities in cases where such entities would have been tax exempt had they been established in France (such as pension funds or a parent company).