This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. On 11 May 2023, the Court of Justice of the European
Dividends received from 95% outside EU held subsidiaries: French corporate tax paid on the fixed proportion of costs and expenses should be claimed
As released in our Tax Alert dated 2 September 2015, the Court of Justice of the European Union concluded in the Groupe Steria SCA case (C-386/14) that the differentiated taxation