The CJEU has held in Groupe Steria SCA that the French taxation of EU-source dividends – which involves including 5% of dividends received from EU subsidiaries in French taxable income but fully exempting dividends received from French tax-consolidated subsidiaries – amounted to discrimination and was incompatible with the freedom of establishment principle in EU law, reports EY.
The CJEU has held in Groupe Steria SCA that the French taxation of EU-source dividends – which involves including 5% of dividends received from EU subsidiaries in French taxable income but fully exempting dividends received from French tax-consolidated subsidiaries – amounted to discrimination and was incompatible with the freedom of establishment principle in EU law, reports EY.