This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. Further to its July 2022 decision that the add-back of a 5%
Court confirms calculation of foreign tax credit to offset dividend lump sum add-back
Supreme administrative court rules on foreign tax credits for certain capital gains
The French Supreme Administrative Court (Conseil d’Etat) canceled on 15 November 2021 the French tax authorities’ (FTA) guidelines denying a tax credit in France for the amount of foreign tax