Request for a preliminary ruling from the Conseil d'Etat in the case Association française des entreprises privées and Others.

Does Article 4 of Council Directive 2011/96/EU of 30 November 2011, (1) and in particular paragraph 1(a) thereof, preclude a levy such as that provided for in Article 235ter ZCA of the General Tax Code, which is payable on the distribution of profits by parent companies that are liable to corporation tax in France and is assessed on the basis of the sums distributed? In the event that the first question is answered in the negative, is a levy such as that provided for in Article 235ter ZCA of the General Tax Code to be regarded as a ‘withholding tax' from which, pursuant to Article 5 of the directive, profits distributed by a subsidiary must be exempt? 

C-365/16

 

 

Informatiesoort: Nieuws

Rubriek: Europees belastingrecht, Vennootschapsbelasting

H&I: Previews

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