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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: France: Dividends

Under the EU Parent/Subsidiary Directive (which is reflected in the terms of Article 11(1)(c)), dividends must be paid gross to a company resident in the United Kingdom that holds at least 10% of the capital of the French company paying the dividend.

For other dividends, the agreement provides for a maximum rate of 15 %. This rate is also available to pension funds that are not companies, notwithstanding that France does not consider such funds to be persons who are resident in the United Kingdom.