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French landmark decision on foreign tax credit imputation for capital gains on shareholdings: an extension to dividends?

In a decision “Air Liquide” dated 15 November 2021, the French Administrative Supreme Court (Conseil d’Etat) ruled for the first time that French resident companies realising capital gains upon the alienation of eligible participation (titres de participation – generally presumed...

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foreign credit

French landmark decision on foreign tax credit imputation for capital gains on shareholdings: an extension to dividends?